Truself Health Group
INFORMATIVE TEXT REGARDING THE PROCESSING OF PERSONAL
DATA
This informative text has been prepared in accordance with the Law No. 6698
on the Protection of Personal Data (“KVKK”), the General Data Protection
Regulation (“GDPR”), the Regulation on Personal Health Data, and the
Communiqué on the Procedures and Principles to Fulfill the Obligation of
Disclosure, to inform data subjects about the procedures and principles
related to the processing of personal data of patients/clients applying to Truself Health Group (“Truself Health Group”).
Ensuring the security of patients’/clients’ personal data is one of the primary
objectives of Truself Health Group. Therefore, to ensure the secure
processing of patients’/clients’ personal data and to prevent any unlawful
access or leakage of such data, all necessary security measures are taken by
Truself Health Group in accordance with the applicable regulations.
DATA CONTROLLER
Your personal data will be processed by TRUSELF SAĞLIK TURİZM VE DANIŞMANLIK HİZMETLERİ LİMİTED ŞİRKETİ (“Truself Health Group”),
located at “Kervangeçmez Sok. Dilan Pasajı No:9/2A, Dükkan No:7, Şişli/Istanbul/Turkey”,
under the Law No. 6698 (KVKK) and GDPR.
Truself Health Group, registered with the Kadıköy Tax Office under Tax ID
8591407230, is considered the “Data Controller” under KVKK and the
“Controller” under GDPR.
Truself Health Group has entered into an agreement with a Law Firm
specializing in Personal Data Protection as the “Data Protection Officer” in
accordance with GDPR, and the compliance process regarding the protection
of personal data at Truself Health Group has
been carried out under the consultancy and guidance of the specialized law
firm, with the operational responsibility resting with the Data Controller.
THE PERSONAL DATA THAT WILL BE PROCESSED
Your personal data and special categories of personal data listed below will be
processed in accordance with the fundamental principles set forth in Article 4
of the KVKK and Article 5 of the GDPR, consistent with the conditions and
purposes specified in Articles 5 and 6 of the KVKK and Articles 6 and 9 of the
GDPR, and as outlined in this Informative Text; ensuring that it is lawful,
purpose-related, limited, and proportional, and processed accurately and up to
date with all necessary technical and administrative measures provided in the
legislation for data security. The personal data processed by
Truself Health Group includes:
1. IDENTITY INFORMATION: Your first name, last name, Turkish ID
Number and/or Passport Number and/or Temporary Turkish ID Number,
place and date of birth, marital status, gender, profession, signature,
and other identifying information.
2. CONTACT INFORMATION: Your address (residence/workplace),
phone number (reported home/workplace landline and/or mobile
numbers), email address, IP address, social media accounts, and other
communication data.
3. HEALTH INFORMATION: Your blood type, allergies, chronic diseases,
sexually transmitted infections, infectious diseases, data regarding
previous surgeries/operations, medications you use regularly,
information regarding Covid-19, your medical treatments, medical
history, health reports, test and imaging results, anesthesia information,
prescription details, harmful health habits, body analysis and
measurement data, skin analysis data, and other health data necessary
for treatments and operations performed on you along with findings
from examinations.
4. PHOTO/VIDEO RECORDINGS AND AUDIO DATA: Your image and
audio data recorded in photographs and/or videos taken before, during,
and/or after the medical procedure, as well as your image and audio
data recorded by closed-circuit security cameras for the purpose of
ensuring workplace security."
5. FINANCIAL INFORMATION: Your bank account number, IBAN, credit
card information, invoicing details, and other financial data.
6. TRANSFER AND ACCOMMODATION INFORMATION: If you are a
health tourist coming within the scope of International Health Tourism,
your transfer information, round-trip flight ticket information, and hotel
accommodation details.
PURPOSES OF PROCESSING YOUR PERSONAL DATA
Your personal data and special categories of personal data will be processed
by Truself Health Group for the following purposes:
Creating a patient file, conducting examinations, preventive healthcare,
medical diagnosis, treatment, medical applications, operations, and care
services; performing follow-up checks after medical diagnosis, treatment, and
operation processes; managing potential complication processes;
communicating directly with you; managing appointment processes; ensuring
patient satisfaction and managing requests; fulfilling legal and contractual
obligations; preserving information that needs to be retained under applicable
regulations regarding your health data for specified durations; consulting with
other relevant specialists when necessary for the correct execution of your
operations/treatments; fulfilling legal obligations applicable to International
Health Tourism; ensuring workplace safety; planning transfer,
accommodation, and interpreter services for health tourist patients/clients;
announcing innovations regarding medical treatments and applications;
informing and educating other physicians; establishing communication with
patients; planning and managing health services and their funding; managing
promotional and marketing activities required under International Health
Tourism incentive legislation; fulfilling responsibilities arising from the legal
relationship established between the doctor and the patient; fulfilling financial,
legal, and administrative obligations; ensuring technical security; and fulfilling
public obligations.
Your personal data and special categories of personal data will be processed
by Truself Health Group under the KVKK and GDPR in the following
situations and conditions:
● Identity Data: Will be processed to conduct examinations, medical
diagnoses, medical applications, treatment/operations, to create patient
files, manage patient satisfaction, and to plan transfer, accommodation,
and interpreter services for health tourists arriving within the framework
of International Health Tourism.
● Contact Information: Will be processed to perform follow-up checks
after medical diagnosis, treatment, and operation processes, manage
appointment processes, and additionally, subject to your explicit
consent, will be processed to promote, inform, and announce
innovations regarding medical treatment and applications.
● Health Data: Will be processed to successfully conduct your medical
treatments and operations, to obtain consultation from another
specialist when necessary, manage potential complication processes,
create patient files, and preserve information regarding your health data
that must be retained under applicable regulations during specified
durations, enabling Truself Health Group to fulfill legal
obligations pursuant to Health Law and International Health Tourism
Legislation.
● Photo, Video, and Audio Recordings: Will be processed by
Truself Health Group to monitor and manage the treatment and/or
operation process, ensure workplace safety, and additionally, subject to
your explicit consent, will be processed to inform third parties medically
about the medical procedures/operations performed on you, and to
manage promotional and marketing activities for international health
tourism regulations concerning foreign individuals.
● Financial Data: Will be processed to monitor your payments for
invoicing purposes and to issue refunds in the event of any
overpayments.
● Transfer and Accommodation Information: Will be processed for
planning transfer and accommodation services for health tourist
patients/clients coming under International Health Tourism.
The personal data mentioned above will be processed for the purposes
described and in accordance with the relevant legislation for the performance
of the medical treatment/operation to be conducted. If you do not provide the
necessary personal data, the legal obligations imposed on ME Here
of the provided
text regarding the processing of personal data:
Truself Health Group as the physician cannot be effectively fulfilled, and your
operation, treatment, and recovery processes cannot be successfully carried
out.
METHOD OF COLLECTING YOUR PERSONAL DATA
Your personal data will be collected in connection with the health services
provided by Truself Health Group as follows:
● By coming to Truself Health Group’s practice for examination,
diagnosis, treatment, or medical application, the health reports,
laboratory results, imaging results, tests, and identification
documents/passports you provide will serve for your medical evaluation
and will include your health data and declarations regarding your
identity and contact information.
● By filling out the “Patient Information and Consent Form” related to your
treatment and/or operation conducted by Truself Health Group.
● Through the contact form you fill out on Truself Health Group’s
corporate website www.truselfhealthgroup.com.
● Through emails sent to Truself Health Group’s corporate email
addresses (info@truselfhealthgroup.com).
● Through photographs and/or video recordings taken before, during,
and/or after your medical procedure.
● Upon your request and where necessary; through online consultation
and controls via remote access provided you accept the relevant
Privacy Policies and Abroad Transfer Principles using remote
connection application service providers
(WhatsApp/Zoom/Facetime/Skype/Messenger/Google/Instagram/Faceb
ook/TikTok, etc.) by sending written/audio/visual (photograph and/or
video recordings) messages or making audio/video calls to
Truself Health Group.
● By sending a direct message to the profile account of
Truself Health Group on social media accounts (Instagram, YouTube,
Facebook, TikTok, Twitter, LinkedIn, etc.) that you currently use, and/or
commenting on their posts, after accepting the respective Privacy
Policies and Abroad Transfer Principles.
● By automatically providing your information through “contact us” or “get
information” panels in promotional and advertisements made by Truself Health Group on the social media accounts (Instagram,
YouTube, Facebook, TikTok, Twitter, LinkedIn, Google, etc.) that you
use, after accepting the respective Privacy Policies and Abroad
Transfer Principles.
● By directly messaging the profile of Truself Health Group on social media accounts (Instagram, YouTube,
Facebook, TikTok, Twitter, LinkedIn, etc.) using the applications you are
currently using, and by agreeing to their respective Privacy Policies and
Abroad Transfer Principles.
● For the purpose of ensuring workplace security within the scope of the
legitimate interests of Truself Health Group, image and audio data
may be recorded through closed-circuit security cameras equipped with
audio recording capability.
Your personal data will be collected for examinations, medical diagnoses,
treatments, operations, and care services, by Truself Health Group,
ensuring compliance with all administrative and technical measures mandated
by KVKK and GDPR.
PURPOSE, METHOD, AND LEGAL BASIS FOR PROCESSING YOUR
PERSONAL DATA
Your personal data will be processed by natural or legal persons authorized
by Truself Health Group, acting as "DATA PROCESSOR," through
verbal, written, camera, and photographic recordings, maintaining records in
physical and electronic environments, and with all necessary technical and
administrative measures mandated by applicable legislation. In situations
specified by the relevant provisions of the KVKK and GDPR, your explicit
consent may be obtained.
SITUATIONS WHERE YOUR EXPLICIT CONSENT IS REQUIRED
According to GDPR Article 6(1)(a) and KVKK Article 5(1), your personal data
may only be processed with your explicit consent in the following situations:
● Sending SMS messages and/or emails and establishing mobile
communication for the announcement, promotion, and information of
innovations regarding the medical services provided by
Truself Health Group requires your explicit consent.
● Sharing photographs and/or video recordings taken to track the
development of treatment before, during, and/or after the medical
procedure on the social media accounts (Instagram, YouTube,
Facebook, Twitter, LinkedIn, Google, etc.) and corporate websites of
Truself Health Group also requires your explicit consent.
● As sharing your data through service providers with servers located
abroad is considered "transfer abroad," and requires "explicit consent"
for such transfers, your explicit consent will be sought in these
situations. However, in the following cases, since Truself Health Group will not conduct any transfers abroad, your explicit consent
will not be sought; your explicit consent will be obtained from the service
provider you are a user of:
1. If you send written/audio messages and/or photographs/video
recordings or request remote examination/diagnosis services using
applications you are currently using with servers located abroad
(WhatsApp/Zoom/Facetime/Skype/Messenger/Google/Instagram/Facebook/TikTok, etc.) after accepting the
respective Privacy Agreement and Abroad Transfer Principles, you will have
given your explicit consent for the transfer of your Personal Data and Special
Categories of Personal Data shared with Truself Health Group
through those applications, in accordance with Truself Health Group's
KVK Disclosure Text and Privacy Principles that will be sent to you via the
mentioned applications.
2. If you request to be contacted through electronic mail service providers
(Hotmail, Gmail, Yahoo, etc.) with servers located abroad, after
accepting the relevant Privacy Policy and Abroad Transfer Principles;
you will have given your explicit consent for Truself Health Group to process your Personal Data and Special Categories of
Personal Data shared in the communications, in accordance with Truself Health Group's KVK Disclosure Text and Privacy Principles,
and for the transfer of your data abroad based on the pre-accepted
policies of these service providers.
3. If you apply to advertisements and promotions published by
Truself Health Group on social media service providers with servers
located abroad (Facebook, Instagram, Google, WhatsApp, etc.); by
accepting the Privacy and Abroad Transfer Principles of these social
media services, you provide consent for your data to be automatically
processed and transferred abroad, which will then be sent to
Truself Health Group. Truself Health Group will process and
store these data according to the KVK Disclosure Text and Privacy
Principles relayed through the application. In these situations, you
acknowledge that you accept the processing of your Personal Data and
Special Categories of Personal Data in accordance with
Truself Health Group's Disclosure Text and Privacy Principles, as well as
the communication through your provided contact information.
4. If you send a direct message to the profile of Truself Health Group on social media accounts (Instagram, YouTube, Facebook,
TikTok, Twitter, LinkedIn, etc.) that you are currently using, while
accepting the respective Privacy Policies and Abroad Transfer
Principles; you will have consented for Truself Health Group to
process your data in accordance with the KVK Disclosure Text and
Privacy Principles sent to you through the application and to
communicate with you through that application.
SITUATIONS WHERE YOUR DATA MAY BE PROCESSED WITHOUT
YOUR EXPLICIT CONSENT:
According to GDPR Article 9(2)(h) and KVKK Article 6(3):
● Your health data, which is considered Special Categories of Personal
Data, will be processed without your explicit consent by
Truself Health Group, who is under a legal obligation of confidentiality,
for the purpose of conducting examinations, medical diagnoses,
treatments, operations, and care services.
According to GDPR Article 6(1)(b) and KVKK Article 5(2)(c):
● After medical diagnosis, treatment, and operational processes, your
personal data will be processed without your explicit consent by Truself Health Group for the purposes of conducting follow-up
checks, managing potential complication processes, communicating
directly with you, and managing appointment processes.
According to GDPR Article 6(1)(f) and KVKK Article 5(2)(f):
● Your personal data will be processed without your explicit consent by
Truself Health Group based on our legitimate interests to
manage legal processes, ensure patient satisfaction and request
management, and ensure workplace security.
According to GDPR Article 6(1)(c), KVKK Article 5(2)(a), and KVKK Article
5(2)(ç); your personal data will be processed without your explicit consent
under the following circumstances:
● Creation of patient files.
● Preservation of information regarding your health data that must be
retained according to the relevant legislation.
● Invoicing by monitoring your payments.
● Fulfillment of tax obligations.
● Fulfillment of obligations required by the Ministry of Health regulations.
● Fulfillment of obligations required by international health tourism
regulations.
● Ensuring your data security.
● Fulfilling legal obligations before judicial authorities.
● Fulfilling administrative obligations before administrative institutions and
organizations.
TRANSFER OF YOUR PERSONAL DATA AND WHO IT WILL BE
TRANSFERRED TO, AND FOR WHAT PURPOSE
Your personal data collected based on the conditions and purposes outlined in
Articles 5 and 6 of Law No. 6698 regarding the Protection of Personal Data
and Articles 6 and 9 of the GDPR will be transferred by Truself Health Group according to Articles 8 and 9 of the KVKK and Articles 45 and 49 of
the GDPR for purposes such as conducting medical examinations, diagnoses,
treatments, medical
applications, operations, and care services, improving these services,
obtaining consultations from specialists when necessary, fulfilling
administrative obligations related to international health tourism, planning
transfer, accommodation, and interpreter services for health tourist patients,
making presentations at scientific congresses, publishing articles in scientific
journals, informing and educating other physicians medically, establishing
communication with patients, planning and managing health services and
funding, managing promotional and marketing activities in accordance with
international health tourism incentive legislation, ensuring workplace safety,
fulfilling responsibilities arising from the legal relationship established between
the doctor and the patient, and fulfilling financial, legal, and administrative
obligations, ensuring technical security, and fulfilling public obligations.
Your personal data processed in this context may be transferred to the
following third parties and organizations:
● Insured Employees,
● Private Hospitals,
● Other specialist physicians for consultation purposes,
● Other physicians for scientific training purposes,
● Suppliers, including:
● Financial Advisors, Tax and Finance Consultants and Auditors,
● Legal Advisors,
● Translators,
● International Promotion Advisors,
● Web Consultants,
● Support Management System (DYS) Officials,
● Data Protection Officers,
● IT Consultants,
● Travel Agencies,
● Providers of "Clinical Management Software,"
● Hotels,
● Database (Server) Providers,
● Public institutions and organizations authorized under the laws,
● Judicial authorities.
STORAGE PERIODS FOR YOUR PERSONAL DATA
● Your identity information will be stored for 20 years after the service
provided to you has ended.
● Your contact information will be stored for 20 years after the service
provided to you has ended.
● Your health information will be stored for 20 years after the service
provided to you has ended.
● Your photo and video information will be stored for 20 years after the
service provided to you has ended.
● Your financial information will be stored for 5 years after the service
provided to you has ended.
DURATION OF PERSONAL DATA PROCESSING
Your personal data will be retained by Truself Health Group to the
extent they are legally required to store. Documentation and retention
obligations arise from local norms related to trade, tax, and health legislation.
The storage periods for your personal data are indicated in the table below.
AGE LIMIT FOR DATA SUBJECT UNDER THE LAW
Under the KVKK, patients/clients must be at least 18 years of age to provide
direct consent for the processing of their personal data. Consent for those
under this age must be provided by their legal representatives.
Under GDPR, patients/clients who are citizens of EU countries or reside in EU
countries can provide direct consent for processing their personal data if they
are at least 16 years old or meet the age limit stipulated in their country.
Consent for those below this age must also be provided by their legal
representatives.
WITHDRAWAL OF CONSENT
If you provide explicit consent to Truself Health Group for the
processing of your personal data, please note that you have the right to
withdraw that consent at any time as specified in GDPR Article 6(1)(a) and
KVKK Article 5(1). If you submit your withdrawal request to the contact
address mentioned below, your consent will be revoked.
RIGHTS OF DATA SUBJECTS UNDER GDPR
As a data subject, your personal data is also protected under GDPR. In cases
where GDPR applies (for EU citizens or residents), the rights of data subjects
are as follows:
● Right of Access (GDPR Article 15): The data subject has the right to
confirm whether their personal data is being processed by
Truself Health Group and to obtain information regarding the details of
such processing.
● Right to Rectification (GDPR Article 16): The data subject has the right
to request the rectification of any personal data that is incorrect or
incomplete held by Truself Health Group.
● Right to Erasure (GDPR Article 17): The data subject has the right to
request the deletion of their personal data held by Truself Health Group. In cases where the conditions described in Article 17 occur,
Truself Health Group will delete the personal data without
delay.
● Right to Restriction of Processing (GDPR Article 18):
● In cases where data subjects challenge the accuracy of their
personal data, they have the right to request a restriction on
processing until the accuracy is confirmed.
● If the processing is unlawful and the data subject requests
deletion, they can request the restriction of processing until their
request is fulfilled.
● If Truself Health Group no longer needs personal data
but the data subject wants it restricted to establish, exercise, or
defend legal claims, they can request the restriction of
processing.
● Data subjects may also request restriction of processing if they
object to the processing based on the provided legitimate grounds
until it is confirmed whether Truself Health Group’s
legitimate reasons for processing outweigh the data subject's
legitimate reasons.
● Right to Data Portability (GDPR Article 20): The data subject has the
right to request the transfer of their personal data held by
Truself Health Group to another controller in a structured, commonly
used, and machine-readable format where technically feasible. This
right may be exercised when the processing is based on consent or
contract.
● Right to Object (GDPR Article 21):
● The data subject has the right to object to the processing of
personal data, including profiling, based on their specific situation
under GDPR Article 6(1)(e) or (f). Truself Health Group
cannot process personal data unless it can demonstrate
compelling legitimate grounds for the processing that override the
interests, rights, and freedoms of the data subject or where
processing is necessary for the establishment, exercise, or
defense of legal claims.
● The data subject has the right to object to the processing of
personal data for direct marketing purposes, including profiling
related to such marketing. If the data subject objects to the
processing of personal data for direct marketing purposes, such
data will no longer be processed for those purposes.
RIGHTS OF DATA SUBJECTS UNDER KVKK
Individuals whose personal data is processed have the following rights under
Article 11 of the KVKK:
● To learn whether their personal data is being processed,
● To request information about their processed personal data,
● To know the purpose of processing personal data and whether it is
being used in accordance with that purpose,
● To know the third parties to whom their personal data has been
transferred, either domestically or abroad,
● To request the correction of personal data if it is incomplete or
incorrectly processed, and to request that this correction be
communicated to third parties to whom their personal data has been
transferred,
● To request the deletion or destruction of personal data when the
reasons for processing no longer apply, and to have this action
communicated to third parties to whom their personal data has been
transferred,
● To object to any negative result arising from the analysis of processed
data through solely automated systems,
● To request compensation for damages incurred due to unlawful
processing of personal data.
If you wish to exercise any of the aforementioned rights or have requests,
please clearly specify which right you would like to invoke in your written
application, which should be submitted in person at the address of
Truself Health Group, located at "Kervangeçmez Sok. Dilan Pasajı No:9/2A, Dükkan No:7
Şişli/Istanbul/Turkey," with a wet signature and identification documents.
Alternatively, you can send it via notary or submit it with a secure electronic
signature to the corporate email address info@truselfhealthgroup.com. You
may also use other methods specified in the KVKK. It is mandatory for your
application to include your full name, signature, Turkish ID Number/Passport
Number/Temporary Turkish ID Number, residence or workplace address,
email address, phone and fax numbers, and the subject of your request,
according to the "Communiqué on Application Procedures and Principles to
the Data Controller."
Truself Health Group will respond to your request as soon as possible
and no later than thirty (30) days from the date of the request, free of charge.
However, if the process incurs additional costs, a fee will be charged based on
the tariff set by the Personal Data Protection Board.
CONSENT AND APPROVAL
When you read and accept this Information Notice, you shall be deemed to
have represented, accepted and undertaken that you have been fully informed
about the data processing performed by Truself Health Group, you
have understood your rights specified in KVKK and GDPR and you have
provided a consent based on your free will in connection with the
PROCESSING of your Personal Data and Special Categories of Personal
Data by Truself Health Group in accordance with this Information
Notice.
You have right not to accept the Information Notice upon reading it.
Truself Health Group identifies itself as the “DATA CONTROLLER”
under KVKK and as the “CONTROLLER” under GDPR.
Respectfully,