PERSONAL DATA PROTECTION POLICY AND GENERAL DISCLOSURE TEXT

EMP Sağlık Turizm Anonim Şirketi  (“Company”) attaches utmost importance to protecting the fundamental rights and freedoms of individuals, especially the privacy of private life regulated in Article 20 of the Constitution, in the protection and processing of personal data. In this context, in accordance with the Law on the Protection of Personal Data No. 6698 (“Law” or “KVK Law”), it pays attention to the protection and processing of personal data in accordance with the law and acts with this care in all its planning and activities. Our Company does not consider the protection and processing of personal data only within the scope of compliance with the legislation, but also puts the value it gives to human beings at the basis of its approach.  

Personal data refers to any information relating to an identified or identifiable natural person. Since the information belonging to the legal entity does not constitute personal data, it is not protected within the scope of KVKK No. 6698. 

Personal data of special nature refers to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing and clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data. 

Processing of personal data; refers to any operation performed on personal data such as obtaining, recording, storing, preserving, changing, rearranging, disclosure, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system. 

Data Controller 

This policy and clarification have been prepared by EMP Sağlık Turizm Anonim Şirketi  as the data controller in accordance with the provisions of KVKK No. 6698 and related legislation. 

The reason for being announced on the website is to provide transparent information about our company’s transactions regarding personal data processes. Our company uses process-based, specific clarification texts while carrying out its business and transactions and aims to provide information about the general framework with this clarification text. 

Address : Küçükbakkalköy Mahallesi Yenidoğan Caddesi No: 25 A Ataşehir – İstanbul – Turkey

Telephone : +90 5413450722 

E-Mail :[email protected] 

Trade Register Number : 368681-5 

Mersis Number : 0334111875900001 

 

Our company carries out data processing activities in the following categories:

Personal data	Identity Communication  Aslam  Legal action  Patient procedure   Physical space security  Process security  Finance  Marketing  Professional experience Audio visual recordings
Special Quality Personal Data	Health Information Criminal Convictions and Security Measures  Trade Union Membership

  

The persons whose personal data are processed are as follows:  

Identity	Employee Candidate Employee  Supplier Employee  Supplier Representative  Sick  Potential Patient  Patient’s Relative
Communication	Employee Candidate Employee  Shareholder/Partner  Supplier Employee  Supplier Representative  Sick  Potential Patient  Patient’s Relative
Aslam	Employee Candidate Employee
Legal Action	Employee
Patient Procedure	Potential Patient Patient’s Relative
Physical Space Security	Employee Candidate Employee  Potential Patient  Supplier Employee  Supplier Representative  Sick  Patient’s Relative
Transaction Security	Employee
Finance	Employee Supplier Representative  Sick
Professional Experience	Employee Candidate Employee
Marketing	Potential Patient  Sick  Website Visitors
Audio Visual Recordings	Employee Sick  Potential Patient
Health Information	Employee Sick
Criminal Convictions and Security Measures	Employee

  

Our Company processes the aforementioned personal data for the following purposes: 

Identity	Execution of Information Security Processes Execution of Application Processes of Employee Candidates  Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees  Conducting Activities in Accordance with the Legislation  Execution of Finance and Accounting Works  Execution of Assignment Processes  Follow-up and Execution of Legal Affairs  Conducting Internal Audit / Investigation / Intelligence Activities  Carrying Out Communication Activities  Planning of Human Resources Processes  Execution / Supervision of Business Activities  Carrying out Business Continuity Activities  Execution of Goods / Services Purchasing Processes  Execution of Goods / Services After-Sales Support Services  Execution of Goods / Services Sales Processes  Execution of Customer Relationship Management Processes  Carrying out Retention and Archive Activities  Execution of Contract Processes  Follow-up of Requests / Complaints  Execution of Supply Chain Management Processes  Providing Information to Authorized Persons, Institutions and Organizations  Execution of Management Activities
Communication	Execution of Information Security Processes Execution of Application Processes of Employee Candidates  Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees  Execution of Access Authorizations  Conducting Activities in Accordance with the Legislation  Execution of Finance and Accounting Works  Execution of Assignment Processes  Follow-up and Execution of Legal Affairs  Conducting Internal Audit / Investigation / Intelligence Activities  Carrying Out Communication Activities  Planning of Human Resources Processes  Execution / Supervision of Business Activities  Execution of Goods / Services Purchasing Processes  Execution of Goods / Services After-Sales Support Services  Execution of Goods / Services Sales Processes  Execution of Customer Relationship Management Processes  Carrying out Retention and Archive Activities  Execution of Contract Processes  Follow-up of Requests / Complaints  Execution of Supply Chain Management Processes  Providing Information to Authorized Persons, Institutions and Organizations  Execution of Management Activities
Aslam	Execution of Employee Candidate / Intern / Student Selection and Placement Processes Execution of Application Processes of Employee Candidates  Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees  Execution of Benefits and Benefits Processes for Employees  Conducting Activities in Accordance with the Legislation  Planning of Human Resources Processes  Execution / Supervision of Business Activities  Carrying out Retention and Archive Activities  Execution of Contract Processes  Providing Information to Authorized Persons, Institutions and Organizations
Legal Action	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Conducting Activities in Accordance with the Legislation  Follow-up and Execution of Legal Affairs  Execution / Supervision of Business Activities  Carrying out Retention and Archive Activities  Providing Information to Authorized Persons, Institutions and Organizations
Patient Procedure	Conducting Activities in Accordance with the Legislation Execution / Supervision of Business Activities  Execution of Goods / Services After-Sales Support Services  Execution of Goods / Services Sales Processes  Execution of Customer Relationship Management Processes  Execution of Contract Processes  Providing Information to Authorized Persons, Institutions and Organizations  Execution of Management Activities
Physical Space Security	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Conducting Activities in Accordance with the Legislation  Ensuring Physical Space Security  Execution / Supervision of Business Activities  Ensuring the Security of Movable Goods and Resources  Ensuring the Security of Data Controller Operations  Providing Information to Authorized Persons, Institutions and Organizations
Transaction Security	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Execution of Access Authorizations  Conducting Activities in Accordance with the Legislation  Conducting Internal Audit / Investigation / Intelligence Activities  Carrying Out Communication Activities  Execution / Supervision of Business Activities  Carrying out Business Continuity Activities  Ensuring the Security of Data Controller Operations  Providing Information to Authorized Persons, Institutions and Organizations  Execution of Management Activities
Finance	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Conducting Activities in Accordance with the Legislation  Execution of Finance and Accounting Works  Execution / Supervision of Business Activities  Execution of Goods / Services Purchasing Processes  Execution of Goods / Services Sales Processes  Execution of Contract Processes  Providing information to authorized persons, institutions and organizations
Professional Experience	Execution of Employee Candidate / Intern / Student Selection and Placement Processes Execution of Application Processes of Employee Candidates  Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees  Conducting Activities in Accordance with the Legislation  Execution of Assignment Processes  Planning of Human Resources Processes  Carrying out Retention and Archive Activities  Execution of Contract Processes  Providing Information to Authorized Persons, Institutions and Organizations
Marketing	Execution / Supervision of Business Activities Execution of Service Sales Processes  Conducting Marketing Analysis Studies  Execution of Marketing Processes of Services
Audio Visual Recordings	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Conducting Activities in Accordance with the Legislation  Planning of Human Resources Processes  Execution / Supervision of Business Activities  Carrying out Retention and Archive Activities  Execution of Contract Processes  Providing Information to Authorized Persons, Institutions and Organizations
Health Information	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Execution of Benefits and Benefits Processes for Employees  Conducting Activities in Accordance with the Legislation  Planning of Human Resources Processes  Execution / Supervision of Business Activities  Execution of Goods / Services After-Sales Support Services  Execution of Goods / Services Sales Processes  Carrying out Retention and Archive Activities  Execution of Contract Processes  Follow-up of Requests / Complaints  Providing Information to Authorized Persons, Institutions and Organizations
Criminal Convictions and Security Measures	Fulfillment of Obligations Arising from Employment Contract and Legislation for Employees Conducting Activities in Accordance with the Legislation  Planning of Human Resources Processes  Carrying out storage and archive activities  Execution of Contract Processes  Providing information to authorized persons, institutions and organizations

  

Personal Data Transferred and Purposes of Transfer

The personal data mentioned to be processed above are transferred to the authorized persons, institutions and organizations in the country and to the private law real and legal persons we receive services in order to realize the above-mentioned processing purposes and to provide information to the authorized persons / institutions / organizations. 

Personal Data Collection Method and Legal Reasons

Your personal data is collected through physical and/or electronic forms, contracts. In addition, security camera records are collected with the security cameras in the company and the photo-audio-video records you transmit to our company through our company whatsapp line. 

The legal reason for processing your personal data is that the processing of personal data belonging to the parties to the contract is necessary provided that the data processing activity is explicitly stipulated in the laws, it is directly related to the establishment or performance of the contract, it is mandatory for the company to fulfill its legal obligation, the data processing is mandatory for the legitimate interests of the company, provided that it does not harm your fundamental rights and freedoms, and it is clear in terms of personal data of special nature. is your consent. 

Your Rights as a Business Contact

As the relevant person (the natural person whose personal data is processed), your rights listed in Article 11 of the Law are as follows:  

• To learn whether your personal data is processed or not,
• If your personal data has been processed, to request information about it,
• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom your personal data are transferred at home or abroad,
• If your personal data is processed incompletely or incorrectly, to request their correction, 
• Requesting the deletion or destruction of your personal data (Article 7 of the Law) Within the framework of the conditions stipulated in the article),
• Requesting that correction, deletion and destruction operations be notified to third parties to whom your personal data is transferred,
• To object to the occurrence of a result against you by analyzing the processed data exclusively by means of automated systems,
• To request the compensation of the damage if you suffer damage due to the unlawful processing of your personal data.

Data Security and Right of Application

Your personal data is meticulously protected within the scope of technical and administrative possibilities, and necessary technical and administrative measures are taken. 

Your requests regarding your personal data: 

• Can deliver in writing to our address written above,
• You can send it through a notary,  
• You can send it to the [email protected] address by writing “KVKK Application” in the subject section. 

If your application requires an additional cost, you may need to pay the fee amount in the tariff to be determined by the Personal Data Protection Board. Your requests included in your application will be concluded as soon as possible and within 30 (thirty) days at the latest depending on the nature of the request.