Main Office: VISNEZADE MAH, SULEYMAN SEBA CAD, 79/2, BESIKTAS / ISTANBUL
Phone: +90-539-5541993

PRIVACY POLICY and CLARIFICATION TEXT ON THE PROCESSING and PROTECTION OF PERSONAL DATA

Last Update: 22/03/2023

As Lavoy Sağlık Turizm ve Danışmanlık A.Ş. (“Lavoy Health”), we protect your personal data in the capacity of data controller within the scope of The Law on the Protection of Personal Data numbered 6698, including the secondary legislation, and we attach great importance to the protection of your personal data in accordance to the General Data Protection Regulation (“GDPR”). This Clarification Text on the Processing and Protection of Personal Data (" Text") has been prepared in order to enlighten you about the sources from which we obtain your personal data, our legal reasons for obtaining and processing personal data, for what purposes we process your personal data, whether we transfer personal data and to whom we transfer it, and your legal rights thereto.  

Lavoy Health processes your personal data in accordance with the laws, prevents the unlawful processing of your personal data and illegal access to such data, and has taken all necessary technical and administrative measures to ensure the most appropriate level of security in order to ensure the protection of personal data.

I. DATA SUBJECTS AND THE PERSONAL DATA SUBJECT TO PROCESS

Lavoy Health, as a data controller, processes personal data limited to the following groups of people;

• Our Employees,

• Our Employee Candidates (including reference persons declared by job applicants),

• Our Interns and On-the-Job Trainees,

• Our patients,

• People who are interviewed and contacted for diagnosis, treatment or to receive such services,

• Patient relatives and companions,

• Parties of all kinds of commercial activities or persons with whom we cooperate or will cooperate due to commercial activities, or authorized or employees of companies, (Supply, advertising, support, marketing, accommodation, transportation, reference resources, etc.)

• Shareholders or persons with whom shareholding negotiations are held,

• Our Legal Advisors, Lawyers and Consultants or authorized or employees of consultancy companies,

• Visitors,

• Legal representatives, parents, guardians or guardians of all data owners,

• Persons who are a party in legal processes and their legal representatives,

• Third persons with whom we have contacted, although they do not have a commercial or legal connection with our company.

Identity Data

The name and surname, the nationality of the persons whose data will be processed, the Turkish ID number or the passport number and information, if not a Turkish citizen or temporary Turkish identity number, the place and date of birth, the marital status and the gender information.

Contact Data

All communication-related data such as the residence address, the correspondence address, the mobile phone number, the e-mail address.

Visual and Audio Data

The video and audio recording taken by the closed circuit camera system recorded by the company security cameras, the audio recordings kept in case you contact our call center, the personal data such as recorded photograph or video in line with the special written consent and permission (consent) of the data subject for the purpose of convincing other patient candidates for medical treatment or for medical treatment or for the purpose of confirming the performance of the promotion, research, medical or aesthetic / cosmetic procedure, are the data within this scope.

Personnel Data

The data obtained in accordance with the laws or employment contract regarding personnel transactions such as the start date of the workers, wages, number of working days per month.

Training Data

Data on the educational status of workers, prospective workers, trainees or on-the-job training trainees or other relevant persons.

Job and Occupation Data

It is all data related to the job or profession in terms of employees, employee candidates, trainees or on-the-job trainees or other related persons (including professional experience, diploma, course data).

Comment and Complaint Data

Comment and complaint data transmitted to our Company through the website or other channels, with approval and consent, in order to evaluate the services we offer.

Location or Location Data

Address or location data that individuals transmit by any means and with their own consent.

Transaction Security Data (IP Data and Cookies)

IP address, browser information, website login and password information, (Mac ID, IP address information, website login and password information) are within this scope.

Legal Data

It is all data and enforcement data in relation to people with their capacity as claimant and respondent in any lawsuit or execution proceeding. The data about the employees working in the Company and any person who has a lawsuit or enforcement proceeding against the Company.

Financial Data

It is the data of individuals such as bank account number and IBAN number. It is the data requested and processed in terms of employees, who work in the company, and the patients, who receive services from the company.

Health Data

All kinds of health data obtained during the execution of , preliminary consultation, medical diagnosis, treatment and care services, such as laboratory and imaging results, medical test results, blood group, examination data, prescription information, which must be followed in medical files for legal reasons, processed with the consent of the person.

In addition, the health report and other medical documents in the employee's personnel file are also within this scope.

Vehicle License Plate Data

If the company's car park or private valet service is used, the license plate data is within this scope.

Customer Transaction Data

Call center records, invoice, promissory note, check, box office receipt, order information, request information, etc. data in this scope.

Clothing Data

Size data etc. fixture, uniform, material and shoe size etc. data is in this scope.

Biometric Data

Palm information, fingerprint, retina scan, face recognition etc. data is in this scope.

Risk Management Data

Data processed for the management of commercial, technical and administrative risks are within this scope.

Physical Area Surveillance

Entry and exit registration information of employees and visitors, security camera records are the data within this scope.

Association, Foundation and Union Data

Association and foundation data may be required in social responsibility and workplace organizations, and union data may be required during union dues deduction.

II. PROCESSING OF PERSONAL DATA

A. Obtaining Personal Data

1. The Channels and Means to Collect Personal Data

Your Personal Data is obtained through channels such as;

1.1. As a result of the meeting with our call center,

1.2. As a result of the conversation made over the live support application on our website,

1.3. As a result of the meeting to be made by contacting Lavoy Health doctors or related personnel via phone, WhatsApp Application or e-mail,

1.4. Over the phones used by Lavoy Health marketing and promotion personnel, or via SMS or WhatsApp etc. As a result of the communication established through the applications,

1.5. In case you apply to Lavoy Health, you can communicate with the doctors or related personnel by phone, SMS or WhatsApp etc. As a result of the interviews you will make over the applications,

1.6. In case you apply to Lavoy Health, as a result of face-to-face meetings with doctors or related personnel,

1.7. Personal data of the persons and company officials or employees with whom business relations are made as a requirement of the commercial activity, on the contract and other commercial activity documents, and on the communication platforms,

1.8. As a result of personal data appearing on the contract and other commercial activity documents of our Legal Advisors, Lawyers and Consultants or authorized or employees of consultancy companies, on communication platforms,

1.9. As a result of the applications made through panels such as "contact us" or "get information" through the promotion and advertisement on social media,

1.10. As a result of requesting a mobile phone number for personal data and encryption requested in accordance with the legislation, in order to connect to the broadcast in a private wireless network (Wi-Fi) for guests within the scope of wireless Internet service,

1.11. Obtaining data in the form of recording the MAC ID (Device Identity Information) from the logins to the website,

1.12. Similarly, by other legal means of obtaining data.

B. Purpose of Processing of Personal Data and Legal Reasons

1. Purposes of Collection and Processing of Personal Data

In line with article 20 of the Constitution of Republic of Turkey and the Law on the Protection of Personal Data numbered 6698, your personal data and your personal sensitive personal data may be processed by the data controller Lavoy Health for the purposes of;

1.1. Fulfilling legal obligations and carrying out all kinds of business within the legal framework,

1.2. Fulfilment of the provisions of the contract,

1.3. Providing Health Services (Execution of medical or medical/cosmetic diagnosis, examination, treatment and all kinds of care services)

1.4. Commercial activity and management requirements,

1.5. Sectoral (health) requirements;

1.5.1.Protection of public health, preventive medicine, medical diagnosis, treatment and care services whether or not they are sick,

1.5.2. Sharing the information requested by the Ministry of Health and all other relevant official institutions and organizations in accordance with the health legislation,

1.5.3.Financing your health services, examination, diagnosis and treatment expenses by patient services, financial affairs, marketing departments,

1.5.4. Informing the patients about the appointment through the customer representative, call center and other channels,

1.5.5. Identity confirmation by patient services, other operating units,

1.5.6. Measuring, increasing and researching patient satisfaction by hospital management, patient rights, patient experience departments,

1.5.7. Invoicing by patient services, financial affairs, marketing departments,

1.5.8. To be able to answer all questions and complaints about our health services by the hospital management, patient rights and call center, patient relations department,

1.6. Technical requirements;

1.6.1. Call center, patient relations, planning and management of the internal functioning of the institution by the hospital management,

1.6.2. The quality of service delivery, patient experience, research and analysis made by the IT departments to improve the quality of health services,

1.6.3. Providing training to workers by human resources management and quality departments,

1.6.4. Monitoring and prevention of abuse or unauthorized transactions by the internal audit and data processing department,

1.6.5. Carrying out risk management and quality improvement activities by the quality, information technology departments

1.6.6. Taking all necessary technical and administrative measures within the scope of data security by the hospital management and IT department,

1.6.7. Ensuring the necessary communication by the officials in order to carry out transportation, accommodation and courtesy services within the scope of health tourism,

1.6.8. Patient relations, marketing, call center, participation in campaigns and providing campaign information by the department, designing special content, tangible and intangible benefits on the web and other mobile channels, social media and communicating them to the addressees,

1.6.9. To be able to carry out training and activities by the educational institutions with which the institution cooperates,

2. Legal Reasons for the Processing of Personal Data

Your personal data mentioned above and your sensitive personal data will be processed for legal reasons as regulated under;

• The Fundamental Law on Health Services Basic numbered 3359,

• The Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates,

• The Law on the Protection of Personal Data numbered 6698,

• The Regulation on Private Hospitals,

• The Regulation on Processing of Personal Health Data and Protection of Privacy

• The Identity Notification Law umbered 1774,

• The Labour Law numbered 4857,

• The Social Insurance and General Health Insurance Law numbered 5510,

• The Law on the Protection of Personal Data numbered 6698, as stated in paragraph 3 of Article 6 of the Law, personal data related to health and sexual life can only be used for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing. may be processed by persons or authorized institutions and organizations under the obligation to keep secrets without seeking the explicit consent of the person concerned.


C. TRANSFERRING PERSONAL DATA

Your personal data will be processed within the framework of its provisions and for the purposes described below;

• The Fundamental Law on Health Services Basic numbered 3359,

• The Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates,

• The Law on the Protection of Personal Data numbered 6698,

• The Regulation on Private Hospitals,

• The Regulation on Processing of Personal Health Data and Protection of Privacy

• The Identity Notification Law umbered 1774,

• The Labour Law numbered 4857,

• The Social Insurance and General Health Insurance Law numbered 5510,

and may be shared with the persons below;

• Ministry of Health, sub-units and family medicine centers affiliated to the ministry,

• Private insurance companies (health, pension, life insurance and similar),

• Social Security Institution,

• Ministry of Family, Labor and Social Policies,

• General Directorate of Security and other law enforcement agencies,

• General Directorate of Population and Citizenship Affairs,

• Other authorized official institutions and organizations,

• Turkish Pharmacists Association,

• Judicial authorities, enforcement offices, mediators,

• Laboratories, medical centers, ambulances, medical devices and institutions providing health services in the country or abroad with which we cooperate for medical diagnosis and treatment,

• The health institution to which the patient was referred or the patient himself applied,

• Legal representatives, parents and guardians authorized in writing

• All third parties, real or legal, from whom consultancy services are received, including lawyers, tax consultants and auditors we work with under the contract,

• Regulatory and supervisory institutions and official authorities,

• Companies within the group of companies that our hospital is affiliated with,

• Banks where our company or the patients or our employees who are related to our company pursuant to any contract, have accounts,

• Private pension companies that work within the scope of compulsory or optional IPS (Individual Pension System),

• Our suppliers, support service providers, archive service providers and business partners whose services we benefit from or cooperate with (for more detailed information, you can obtain information by applying to our hospital in writing.)

• To our business partners and business contacts,

• To our shareholders and real or legal persons with whom shareholder interviews were held.

• Outsourcing service providers,

• Cargo or courier companies,

• Air, land or sea passenger transport companies.

III. DATA SECURITY

As the data controller, Lavoy Health protects the above-mentioned personal and sensitive personal data in its own physical and electronic environments with great sensitivity and by fully complying with the provisions of the legislation, by taking all kinds of administrative and technical measures.

Lavoy Health has taken all kinds of administrative and technical measures to protect your personal data, as recorded in VERBIS and included in the Personal Data Inventory.

Lavoy Health is committed to protecting all personal data. In order to prevent the unlawful processing and access of personal data and to ensure the protection of personal data, technical and administrative measures to ensure the appropriate level of security are carried out by using various methods and security technologies.

Lavoy Health will not disclose the obtained personal data to others in violation of the provisions of the Law on Protection of Personal Data No. 6698 and will not use it for any other purposes than processing.

Lavoy Health has prepared and signed all warning or consent statements, undertakings, and has implemented the necessary multi-faceted audit activities for cases where it is necessary and necessary to share (transfer) personal data with outsource service providers and suppliers, consultants or lawyers.

IV. PROCESSING OF PERSONAL DATA COLLECTED THROUGH COOKIES

Lavoy Health does not position cookies on its website. During the use of our website and mobile application, IP address, browser information. (Mac ID, IP address information, website login and password information) are not received.

V. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

The Article 20 of the Republic of Turkey’s Constitution states that everyone has the right to be informed about the personal data related to him/her, and as per Article 11 of the Law on Protection of Personal Data No. 6698, the right to "request information" is among the rights of the Personal Data owner. In this context, Lavoy Health provides the necessary information if the personal data subject requests information, and with this Clarification Text, Lavoy Health informs the data subject about how the right to request information is used and how the issues related to the information request will be evaluated.

A. Your Rights in Relation to Your Personal Data

In relation to the processing of your personal data, you have the rights of;

1. Learning whether your personal data is processed or not,

2. If your personal data has been processed, requesting information about it,

3. Learning the purpose of processing your personal data and whether they are used in accordance with the purpose,

4. Knowing the third parties to whom your personal data is transferred, in the country or abroad,

5. Requesting correction of personal data if it is incomplete or incorrectly processed

6. Requesting the deletion or destruction of personal data,

7. In case your personal data has been transferred to third parties, requesting that your personal data be corrected and deleted or destroyed, in case your personal data is incomplete or incorrectly processed, to be notified or forwarded to the relevant third party,

8. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

9. Demanding the removal of the damage in case of loss due to the illegal processing of personal data.

Lavoy Health will collect Personal Data only for precise, clear and legal purposes and may store the Personal Data for the periods required by the processing purposes of the Personal Data described in the relevant section above, and the Personal Data will be kept within the framework specified in the Law on Protection of Personal Data No. 6698 and this Clarification Text. they will not be processed in a way incompatible with the purposes for which they were collected, and in the event that the reasons requiring their processing disappear, they will be deleted or destroyed or anonymized ex-officio or upon the request of the data owner, without prejudice to the legally obligatory storage conditions.

Personal data collected about persons under the age of 18 are limited to their name, surname, age and degree of affinity, and these data can only be given to us by the relevant adult (parent or guardian).

B. Means of Contact to Exercise Your Rights

Your rights under the Personal Data Protection Law can be exercised;

1. By filling out the Application Form on the Protection of Personal Data on the "www.lavoyhealth.com" website of our company,

2. Coming to the address of Vişnezade Mahallesi Süleyman Seba Caddesi No:79/2C Beşiktaş İstanbul, where our company is headquartered, filling in the Application Form on the Protection of Personal Data to be obtained from the Human Resources Management department and handing it in person against signature,

3. By sending a letter through the notary public,

4. By sending an e-mail to info@Lavoyhealth.com with secure electronic or mobile signature, to the registered e-mail address.

According to the nature of your request and your application method, additional verifications (such as sending a message to your registered phone, calling) may be requested by the Company in order to determine whether the application belongs to you or not, and thus to protect your rights. For example, if you apply through your e-mail address registered with the Company, you can be contacted using another communication method registered with the Company and you may be asked to confirm whether the application belongs to you.

As a rule, your requests in your application will be concluded free of charge within thirty working days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost for the Company, a fee may be charged as stated in the Communiqué on the Procedures and Principles of Application to the Data Controller published in the Official Gazette dated 10.03.2018 and numbered 30356 by the Personal Data Protection Authority. If your application is caused by the fault of our company, which is the Data Controller, the paid fee will be refunded to you.

Your requests for the Protection of Personal Data will generally be concluded free of charge, within thirty business days at the latest, as of their receipt by our Company.

Lavoy Health has the right to request some confirmatory information from you in order to confirm that you are the right person in case of your application. Unless you cancel your application, you are deemed to have accepted these requests of Lavoy Health.

CONTACT INFORMATION

Lavoy Sağlık Turizmi ve Danışmanlık A.Ş.

Website: www.lavoyhealth.com

E-Mail: info@lavoyhealth.com

Address: Vişnezade Mahallesi Süleyman Seba Caddesi No:79/2C Beşiktaş Istanbul