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KOÇ HEALTHCARE INTERNATIONAL PRIVACY NOTICE
Pursuant to the Law on the Protection of Personal Data No. 6698 (the “Law”), your personal data may be processed within the scope set out below by Moment Eğitim Araştırma Sağlık Hizmetleri ve Ticaret Anonim Şirketi (the “Institution”), acting as data controller.
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Identity of the Data Controller
Company Name: Moment Eğitim Araştırma Sağlık Hizmetleri ve Ticaret Anonim Şirketi
MERSIS Number: 0068078344100012
Address: Güzelbahçe Sok. No:20, Şişli, Istanbul, Türkiye
Telephone: +90 212 311 20 00
Email: kisiselveri@amerikanhastanesi.org
Registered Electronic Mail (KEP) Address: momentegitimarastirma@hs02.kep.tr
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Categories and Types of Personal Data Processed
Categories of Personal Data
Types of Data
Identity Information
Your name, surname, Turkish ID number / passport number, date of birth, place of birth, gender, nationality
Contact Information
Your address, e-mail address and phone number
Customer Transaction Information
Information regarding your appointment scheduling transactions, application and service utilization processes, and records relating to your use of services within our Institution
Transaction Security Information
Your IP address, website and system usage information, user transaction records, log records, and information regarding device and connection security
Financial Information
Invoice and current account information, bank account information and credit card information
Marketing Information
Information regarding your commercial electronic communication preferences processed to the extent permitted under applicable legislation, as well as data relating to your satisfaction evaluations and information processes
Visual and Audio Records
Your visual and audio recordings
Health Information
Health-related information that you voluntarily provide in the message field, such as information concerning your medical condition, diagnosis, medical history, treatment or other health-related matters;
Sexual Life Information
Information concerning your sexual life that may be contained in medical reports, examination results, medical records or other documents voluntarily provided by you, where such information is relevant to the assessment of your healthcare needs;
Genetic Data Information
Where applicable, your genetic test results, molecular analysis results and assessment information regarding hereditary diseases
Transaction Information
Transaction information relating to your application, registration, pre-authorization, invoicing, collection, appointment and service delivery processes
Family Members and Relatives Information
Information regarding your relatives, including name, surname, degree of kinship, contact information, emergency contact person and companion information
Request and Complaint Information
Information regarding your requests, complaints, suggestions and satisfaction notifications, as well as application and evaluation records
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Processed Personal Data, Purposes of Processing and Legal Grounds
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Your personal data collected may be processed for the purposes (“Purposes”) and based on the legal grounds set out below, in accordance with Articles 5 and 6 of the Law.
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Categories of Personal Data
Purpose of Processing
Legal Ground
Identity Information, Contact Information, Customer Transaction Information, Transaction Information, Request and Complaint Information
Receiving, evaluating and responding to inquiries and second opinion requests; communicating with the data subject; establishing and performing the relevant service relationship and coordinating the related processes.
Article 5(2)(c) of the Law – processing is necessary for the establishment or performance of a contract.
Identity Information, Contact Information, Transaction Security Information, Financial Information, Visual and Audio Records, Transaction Information, Request and Complaint Information
Planning and execution of patient relationship management processes; conducting information security processes; conducting audit and ethics activities; planning and execution of internal operational processes within the Institution; conducting and supervising business activities aimed at the effective provision of healthcare services; carrying out data analysis processes for the improvement of healthcare services; conducting management activities; managing and maintaining business operations.
Article 5(2)(f) of the Law – processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.
Identity Information, Contact Information, Transaction Information, Request and Complaint Information
Fulfilling legal and regulatory obligations; responding to requests from competent authorities and carrying out processes required by applicable legislation.
Article 5(2)(ç) of the Law – processing is necessary for compliance with a legal obligation.
Health Information, Sexual Life Information, Genetic Data Information
Receiving and evaluating health information and medical documents; assessing the data subject’s health condition; reviewing medical records and relevant documents; providing and coordinating second opinion and medical assessment services.
Article 6(3)(f) of the Law – Processing is necessary by persons under an obligation of confidentiality or authorized institutions and organizations for the purposes of protection of public health, preventive medicine, medical diagnosis, treatment and care services, and planning, management and financing of healthcare services
Marketing Information
Conducting promotional and informational activities and communicating information regarding products and services.
Explicit Consent, where required under applicable legislation.
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Recipients of Your Personal Data and Purposes of Transfer
Your collected personal data may be transferred by our Institution to the following parties within the scope of the Purposes, in accordance with the general principles set out in the Law and within the scope of the personal data processing conditions specified in Articles 8 and 9 of the Law.
Recipient Entities
Purpose of Transfer
Legal Basis
Business partners with whom we cooperate for healthcare services, and institutions under confidentiality obligation such as laboratories, medical centers, ambulance services, medical device and healthcare service providers; hospitals under Vehbi Koç Foundation Healthcare Institutions and Koç Healthcare via Hospital Information Management System (HIMS), affiliates and group companies
Provision of healthcare services, including medical diagnosis, treatment and care processes; ensuring planning, coordination and continuity of healthcare services; and enabling effective and secure service delivery
• Necessary for the establishment or performance of a contract to which the data subject is a party, and/or necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
• For special categories of personal data: necessary for public health protection, preventive medicine, medical diagnosis, treatment and care services, and for the planning, management and financing of healthcare services by persons under confidentiality obligation or competent public authorities.
Legally authorized public institutions and authorized private persons
Execution of legal processes and fulfilment of obligations arising from legislation
• Explicitly stipulated by laws; necessary for compliance with the legal obligation of the data controller; and/or necessary for the establishment, exercise or protection of a right.
Service providers such as medical record archiving companies, digital health information management systems, courier companies, and other suppliers engaged in healthcare service delivery
Execution of healthcare services, including archiving and management of medical records, operation of digital health information systems, delivery of medical documents and materials, and ensuring continuity, security, and efficiency of such processes
• Necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject.
• For special categories of personal data: necessary for public health protection, preventive medicine, medical diagnosis, treatment and care services, and for the planning, management and financing of healthcare services by competent authorities or persons under confidentiality obligation.
Microsoft Ireland Operations Limited
Conducting information security processes; managing access authorizations; communication activities; business operation execution/supervision; contract processes; providing information to authorized persons and institutions; and management activities
Transfer is based on the existence of a standard contractual clause announced by the Board, including provisions regarding data categories, purposes of transfer, recipients and recipient groups, technical and organizational measures, and additional safeguards for special category personal data.
Method of Collection of Your Personal Data
Your personal data are collected by the Institution within the scope of fulfilling the Purposes through electronic channels such as our websites, mobile applications, Call Center, Koç Healthcare Patient Portal, our systems including the integrated hospital information management system, portal(s) through which online services are provided, social media platforms, and e-mail channels; and through physical channels such as courier/post, fax, closed-circuit camera recording systems (CCTV), and face-to-face meetings. Where certain benefits and opportunities regarding the Institution’s services are provided to your relatives within the scope of agreements that may be concluded between the Institution and contracted insurance companies, your personal data may also be obtained through the information and documents provided by such relatives.
Retention Period
Your personal data will be retained for the period necessary to fulfil the purposes described in this Privacy Notice and for the periods required or permitted under applicable legislation. Once the relevant retention periods have expired, or where the legal grounds requiring the processing no longer exist, your personal data will be deleted, destroyed or anonymized in accordance with applicable legislation.
Your Rights as a Data Subject Under Article 11 of the Law
As a data subject, you may submit your requests regarding your personal data processed by us under Article 11 of the Law, in accordance with the Communiqué on the Principles and Procedures for Application to the Data Controller. Your requests may be submitted at any time in writing, or via registered electronic mail (KEP), secure electronic signature, mobile signature, or using the e-mail address you have previously notified to us and which is registered in our systems.
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Email: kisiselveri@amerikanhastanesi.org
Registered Electronic Mail (KEP) Address: momentegitimarastirma@hs02.kep.tr
Address: Güzelbahçe Sok. No:20, Şişli, Istanbul, Türkiye