PRIVATE ALPİN ORAL AND DENTAL HEALTH SERVICES INDUSTRY AND TRADE LIMITED COMPANY INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

This Information Notice has been prepared by PRIVATE ALPİN ORAL AND DENTAL HEALTH SERVICES INDUSTRY AND TRADE LIMITED COMPANY (the “Company”) to inform its customers regarding the processing of personal data by the Company in accordance with the Law on the Protection of Personal Data No. 6698 (the “Law”).

You can find detailed information regarding the processing of your personal data under this Information Notice at the Personal Data Protection and Processing Policy of PRIVATE ALPİN ORAL AND DENTAL HEALTH SERVICES INDUSTRY AND TRADE LIMITED COMPANY, available at [www.dentalpin.com.tr].

a) Methods of Obtaining Personal Data and Legal Reasons Your personal data is collected in electronic or physical environments. The personal data collected for the legal reasons specified in this Information Notice can be processed and shared within the framework of the personal data processing conditions stipulated in Articles 5 and 6 of the Law.

b) Purposes of Processing Personal Data Your personal data is processed by the Company in accordance with the personal data processing conditions specified in Articles 5 and 6 of the Law for the following purposes: planning and executing the activities necessary for customizing the products and services offered by the Company according to the preferences, usage habits, and needs of relevant individuals; conducting necessary works by business units to enable relevant individuals to benefit from the products and services provided by the Company; carrying out necessary works by business units to perform the commercial activities conducted by the Company and executing related business processes; planning and executing the Company’s commercial and/or business strategies; and ensuring the legal, technical, and commercial-security of the Company and individuals in business relationships with the Company.

c) Parties to Whom Personal Data May Be Shared and Purposes of Sharing Your personal data may be shared with the Company’s business partners, suppliers, legally authorized institutions and organizations, and legally authorized private legal entities within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law for the following purposes: planning and executing the activities necessary for customizing the products and services offered by the Company according to the preferences, usage habits, and needs of relevant individuals; conducting necessary works by business units to enable relevant individuals to benefit from the products and services provided by the Company; carrying out necessary works by business units to perform the commercial activities conducted by the Company and executing related business processes; planning and executing the Company’s commercial and/or business strategies; and ensuring the legal, technical, and commercial-security of the Company and individuals in business relationships with the Company.

d) Rights of Data Subjects and Use of These Rights As data subjects, you can communicate your requests regarding the rights listed below to the Company using the methods specified under the title “Rights of Data Subjects to be Exercised”. Your requests will be evaluated and concluded by our Company within the shortest time possible and in any case within 30 (thirty) days.

According to Article 11 of the Law, as a personal data owner, you have the following rights:

  • To learn whether your personal data is being processed,
  • To request information regarding your personal data if it has been processed,
  • To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
  • To know the third parties to whom your personal data is transferred, domestically or abroad,
  • To request the correction of your personal data if it is incomplete or inaccurately processed, and to request that the operation carried out in this scope be communicated to the third parties to whom your personal data has been transferred,
  • To request the deletion or destruction of your personal data when the reasons necessitating the processing have ceased to exist, even though it has been processed in accordance with the Law and other relevant legislation, and to request that the operation carried out in this scope be communicated to the third parties to whom your personal data has been transferred,
  • To object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems,
  • To request compensation for damages in case you suffer any damage due to the unlawful processing of your personal data.

According to the second paragraph of Article 28 of the Law, the following situations are listed where data subjects do not have the right to request:

  • When personal data processing is necessary for the prevention of a crime or for the investigation of a crime,
  • When personal data has been made public by the relevant individual,
  • When personal data processing is necessary for the performance of supervision or regulation tasks by public institutions and organizations authorized by law, or for the necessary actions in disciplinary investigations or prosecutions,
  • When personal data processing is necessary for the protection of the economic and financial interests of the State in relation to budget, tax, and financial matters, in these cases, the rights mentioned above cannot be exercised.

According to the first paragraph of Article 28 of the Law, in the following cases, data will be outside the scope of the Law, and requests of data subjects regarding these data will not be processed:

  • When personal data is processed by individuals regarding their own activities or those of family members living in the same household, provided that they comply with the obligations related to data security and do not share them with third parties,
  • When personal data is processed for research, planning, and statistics purposes by making it anonymous through official statistics,
  • When personal data is processed for artistic, historical, literary, or scientific purposes, or under the freedom of expression, as long as it does not violate national defense, national security, public safety, public order, economic security, or privacy rights,
  • When personal data is processed by public institutions and organizations authorized by law in preventive, protective, and intelligence activities aimed at ensuring national defense, national security, public safety, public order, or economic security,
  • When personal data is processed by judicial authorities or execution offices in relation to investigations, prosecutions, trials, or enforcement processes.

Use of Rights by Data Subjects

Data subjects can use the aforementioned rights by utilizing the “Application Form for Personal Data Owners to the Data Controller” available at [ww……………..………..com]. Applications will be made using one of the following methods along with documents that identify the relevant data subject:

  • Sending the printed and signed copy of the form by hand, through a notary, or by registered mail to the address [………………………………………………………..-Turkey],
  • Signing the form electronically with a secure electronic signature as regulated under the Electronic Signature Law No. 5070 and sending it to the registered electronic mail address [……………………..@hs02].kep.tr,
  • Following a method prescribed by the Personal Data Protection Board.

The Company responds to data subjects who wish to exercise their rights within the limits specified in the Law within a maximum of thirty (30) days, as mandated by the Law. In order for third parties to apply on behalf of the data subject, a special power of attorney issued through a notary public must be available for the person to whom the application will be made.

As a rule, applications made by data subjects will be processed free of charge, although a fee may be charged in accordance with the fee schedule set by the Personal Data Protection Board【1】. The Company may request information from the applicant to determine whether they are indeed a personal data owner and may ask the data subject questions to clarify the matters mentioned in the application.

【1】 According to the “Communiqué on Principles and Procedures of Application to the Data Controller” published in the Official Gazette dated 10.03.2018 and numbered 30356, no fee will be charged for responses to applications made in writing for up to ten pages. A fee of 1 Turkish Lira may be charged for each page exceeding ten pages. If the response to the application is provided on a recording medium such as a CD or USB memory, the fee requested by the Institution may not exceed the cost of the recording medium.