OZEL DEMIDERM POLIKLINIGI

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

This clarification text has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) contained in the Turkish Legal legislation and the General Data Protection Regulation of the European Union (“GDPR”) in order to inform the data subjects about the procedures and principles related to the processing of Personal Data belonging to patients/advisees who have applied to DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. (“OZEL DEMIDERM POLIKLINIGI”).

One of OZEL DEMIDERM POLIKLINIGI’s highest priorities is ensuring the security of patients’/advisees’ personal data. As a result, in order to securely process the Personal Data of patients/advisees and prevent any unauthorized access or leakage of this data, OZEL DEMIDERM POLIKLINIGI implements the necessary security measures in accordance with applicable legislation.

DATA SUPERVISOR

Your Personal Data will be processed by the DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. -owned OZEL DEMIDERM POLIKLINIGI, which operates at the address “Kültür Mah. Ali Çetinkaya Blv.  No:22 K:4 D:8 Alsancak/İzmir/Turkey” within the scope of KVKK No. 6698. DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. with the Mersis number 0274046496200015 is considered to be the “DATA CONTROLLER” within the scope of KVKK and the “DATA SUPERVISOR” within the scope of GDPR.

OZEL DEMIDERM POLIKLINIGI has signed an agreement with a law firm with Personal Data Protection Expertise as a “Data Protection Officer” within the scope of the GDPR, and the Compliance Process regarding the Protection of Personal Data within the scope of the KVKK and GDPR within the OZEL DEMIDERM POLIKLINIGI has been carried out with the advice and guidance of an expert law firm.

PERSONAL DATA TO BE PROCESSED

Your Personal Data mentioned below will be processed by the OZEL DEMIDERM POLIKLINIGI  in accordance with the basic principles stipulated by Article 4 of the KVKK and Article 5 of the GDPR, Articles 5 and 6 of the KVKK and Articles 6 and 9 of the GDPR for the Purposes and Conditions of Personal Data Processing specified in the OZEL DEMIDERM POLIKLINIGI  will be processed by the OZEL DEMIDERM POLIKLINIGI  in accordance with the basic principles set forth in the GDPR Article 5 and GDPR Article 9 and in accordance with the law, in connection with the purposes of processing, limited and measured, in accordance with the principle of fairness and transparency, in an accurate and up-to-date manner, in order to ensure data security by taking all kinds of technical and administrative measures required by the legislation in order to remain within the scope of the purposes contained in this Clarification Text.

1- PERSONAL IDENTIFYING INFORMATION: Your name, surname, Republic of Turkey Identification Number and/or Passport Number and/or Temporary Republic of Turkey Identification Number, identification information, passport information, place and date of birth, marital status, gender, profession, signature and other identification data that may identify you.

2- CONTACT INFORMATION: Your address (residence/ work), phone number (home/ work fixed and/or mobile phone numbers you have provided), e-mail address, IP address, social media accounts and other contact data.

3- HEALTH INFORMATION: Your blood type, laboratory and imaging results, tests, allergies, chronic diseases, venereal diseases, infectious diseases, data on previous surgeries / operations, medications you use continuously, information about Covid-19 disease, medical treatments, prescription information, skin analysis data, body measurement analysis data, health habits and other health data necessary for treatment and applications to be applied to you.

4-YOUR VOICE RECORDING WITH YOUR PHOTOS AND VIDEO IMAGES: Your image and audio recording data contained in photos and/or videos recorded before, during and/or after a medical procedure, as well as your image data recorded by security cameras located under closed circuit recording to ensure workplace security.

5- FINANCIAL INFORMATION: Your bank account number, IBAN number, credit card information, billing information and other financial data.

6- TRANSFER AND ACCOMMODATION INFORMATION: If you are an International Health Tourist, your transfer information, round-trip flight ticket information, and hotel accommodation information will be provided.

FOR WHAT PURPOSE IS YOUR PERSONAL DATA PROCESSED

Your Personal Data is processed by OZEL DEMIDERM POLIKLINIGI in accordance with the KVKK and GDPR for to be able to create a patient file, to carry out your examination, medical diagnosis, treatment and care services, to carry out your controls after medical diagnosis and treatment processes, to manage complications that may occur, to communicate with you face to face, to manage appointment processes, to perform patient satisfaction and demand management, to fulfill legal and contractual obligations, to be able to bring the information about your health data, which must be kept in accordance with the relevant legislation, to be able to keep the information about your health data within the specified periods, to receive consultation services from other relevant specialist physicians when necessary in order to carry out your treatment correctly, to fulfill legal obligations in accordance with the legislation within the scope of health tourism, to transfer patients/clients coming within the scope of health tourism, to be able to plan accommodation, interpreter services, to announce innovations regarding medical treatment and applications, to inform third parties about the applied medical procedure in medical terms. be able to inform, plan and manage health services and financing, ensure workplace safety, fulfill the responsibilities arising from the legal relationship established between the doctor and the patient, fulfill financial and administrative obligations, provide technical and commercial security and fulfill public obligations purposes.

Your Personal Data will be processed within the scope of KVKK and GDPR by OZEL DEMIDERM POLIKLINIGI in the following situations and conditions:

• Your Identity Data will be processed in order to carry out examination, preventive medicine, medical diagnosis, treatment and care services, create a patient file, perform patient satisfaction and demand management, plan transfer, accommodation and interpreter services of patients / advisees who come within the framework of Health Tourism.
• Your Contact Information will be processed to carry out your checks after the medical diagnosis and treatment processes, to manage the appointment processes, and may also be processed to introduce, inform, announce innovations related to medical treatment and practices, as well as to congratulate and celebrate special occasions, provided that you give your explicit consent.
• Your Health Information will be processed in order to successfully perform your medical treatments and medical aesthetic practices, to get a consultation from another specialist physician if deemed necessary in your treatment process, to create a patient file, to retain information about your health data that must be stored in accordance with the relevant legislation for the duration, to fulfill the legal obligations contained in the current Health Law and Health Tourism Legislation.
• Your Photo, Video and Audio Recording Information will be processed by OZEL DEMIDERM POLIKLINIGI in order to monitor and manage the treatment process, ensure workplace safety, and may also be processed to inform 3rd Parties about the medical procedure applied to you, make a medical promotion, provided that you have explicit consent.
• Your Financial Data will be processed in order to be able to organize invoices by checking your fee payments and to refund your fee if there is any fee surplus.
• Your Transfer and Accommodation Information will be processed in order to plan the transfer and accommodation services of patients /advisees who come within the framework of health tourism.

Your personal data mentioned above will be processed in accordance with the aforementioned purposes and legislation in order to carry out your medical treatment and to fulfill the obligations related to your treatment. If you do not provide your relevant personal data, the legal obligations imposed on OZEL DEMIDERM POLIKLINIGI, which will provide services for your medical treatment, will not be fulfilled as required and your treatment and/or recovery processes will not be carried out successfully.

METHOD OF COLLECTION OF PERSONAL DATA

Your Personal Data will be collected in the following ways depending on the health care provided by OZEL DEMIDERM POLIKLINIGI and will be processed in accordance with KVKK and GDPR in order to enable OZEL DEMIDERM POLIKLINIGI to fully and properly fulfill its contractual and legal obligations throughout the examination, medical diagnosis, treatment and care services:

• By coming to the OZEL DEMIDERM POLIKLINIGI for examination and treatment, your health reports, laboratory and imaging results, analyzes, health reports and statements you have given regarding your health data, in order to make a medical evaluation regarding the treatment to be applied to you,
• By filling in the “Patient Information and Consent Form” regarding the treatment that OZEL DEMIDERM POLIKLINIGI will administer to you,
• By visiting the demiderm.com.tr page of the corporate website of the OZEL DEMIDERM POLIKLINIGI and through the contact form you filled in on this page,
• By e-mails you will send to the corporate e-mail address info@demiderm.com.tr of the OZEL DEMIDERM POLIKLINIGI,
• By means of photo/video recordings recorded before, after and/or during the medical procedure applied to you at the OZEL DEMIDERM POLIKLINIGI,
• By using the remote connection applications service providers that you receive services from by accepting their Privacy Policies and Foreign Transfer Policies, by sending written/audio/visual (photo and/or video recording) messages to OZEL DEMIDERM POLIKLINIGI, company officals and/or responsible manager doctor and by making online audio/video calls that you set up through these applications (WhatsApp / Zoom / Facetime / Skype / Messenger / Google / Instagram / Facebook etc.) so that you can diagnose and check online via remote access by OZEL DEMIDERM POLIKLINIGI at your request and if necessary,
• By sending direct messages and/or commenting on their posts to OZEL DEMIDERM POLIKLINIGI, company officals and/or responsible manager doctor profile accounts belonging to social media accounts (Instagram, YouTube, Facebook, Twitter, LinkedIn, etc.) that you are currently a user of, whose server is located abroad, accepting their Privacy Policies and Foreign Transfer Policies,
• By accepting their own Privacy Policies and Foreign Transfer Policies through the social media accounts that you are currently a user of and whose server is located abroad, by allowing the responsible manager OZEL DEMIDERM POLIKLINIGI, company officals and/or responsible manager doctor to be automatically processed through panels such as “Contact Us” or “Get Information” contained in promotions and advertisements made by your information that you have transferred through your information,
• By means of security cameras that are under closed-circuit recording, which do not have voice recording features, in order to ensure workplace safety within the scope of the legitimate interest of the OZEL DEMIDERM POLIKLINIGI.

THE PURPOSE, METHOD AND LEGAL REASON FOR PROCESSING YOUR PERSONAL DATA

Your Personal Data may be processed by natural or legal persons authorized by the OZEL DEMIDERM POLIKLINIGI as “DATA PROCESSOR / SUPERVISOR”, by taking oral, written, camera and photo records, keeping the necessary technical and administrative security measures together with physical and electronic records, as well as by obtaining your explicit consent in cases where the relevant provisions of the KVKK and GDPR are foreseen, and also by obtaining your explicit consent.

CASES WHERE YOUR EXPLICIT CONSENT MUST BE OBTAINED

In accordance with Article 6/1/a of the GDPR and article 5/1 of the KVKK, your Personal Data may be processed in the following cases only with your explicit consent:

• Sending SMS messages and/or e-mails and mobile communication to you in order to promote, announce and inform about the innovations regarding the medical services provided by OZEL DEMIDERM POLIKLINIGI will only be possible with your explicit consent.
• It will be possible to share your photos and/or video recordings taken before, during and/or after the medical procedure on the social media accounts of OZEL DEMIDERM POLIKLINIGI, company officals and/or the responsible director doctor (Instagram, YouTube, Facebook, Twitter, LinkedIn, etc.) and corporate websites to observe the development of treatment before, during and/or after the medical procedure only with your explicit consent.
• Since the sharing of your data through service providers whose servers are located abroad will be considered a “transfer abroad” and there is an “explicit consent requirement” for the transfer abroad, your explicit consent will be obtained in such cases. However, in the following cases, YOUR EXPLICIT CONSENT WILL NOT BE SOUGHT, as there will be no foreign transfer made by the OZEL DEMIDERM POLIKLINIGI, YOUR EXPLICIT CONSENT WILL HAVE BEEN OBTAINED BY THE SERVICE PROVIDER OF WHICH YOU ARE A USER;

• By accepting the policies of the aforementioned applications, you have accepted the processing of your Personal Data and Private Personal Data that you share with OZEL DEMIDERM POLIKLINIGI through these applications, in accordance with the KVK Clarification Text and Privacy principles to be transmitted to you through the application belonging to OZEL DEMIDERM POLIKLINIGI, and in accordance with the policies you previously accepted of these applications (Instagram, YouTube, Facebook, Twitter, LinkedIn, etc.) whose servers are located abroad, you give express consent to the relevant service provider for the transfer abroad, in the event that you send a written/voice message and/or photo/video recording to OZEL DEMIDERM POLIKLINIGI make a voice, video call, or request to receive a remote examination/diagnosis service by contacting yourself in this way, you agree to the processing of your Personal Data and Specially Qualified Personal Data that you share with us through these applications in accordance with the Text of the KVK and the Privacy principles that will be transmitted to you through the application belonging to us and you give your express consent to the relevant service provider to transfer your data abroad in accordance with the previously accepted policies of these applications located abroad.
• You deemed to have agreed that OZEL DEMIDERM POLIKLINIGI will process your Personal Data and Special Personal Data shared in messages in accordance with its KVK Lighting Text and Privacy principles and given your express consent to your mail service provider to transfer your data abroad in accordance with the previously agreed policies of these service providers whose server is located abroad, in cases where you have requested to be contacted via the electronic mail service providers (Hotmail, Gmail, Yahoo, etc.) whose servers you are already a user of by accepting its Privacy Policy and Foreign Transfer Policies (Hotmail, Gmail, Yahoo, etc.),
• If you apply for advertising and promotions of OZEL DEMIDERM POLIKLINIGI, company officals and/or responsible manager doctor published on social media service providers (Facebook, Instagram, Google, WhatsApp, etc.) whose servers are located abroad, your data that you have allowed to be automatically processed and transferred abroad by accepting the Privacy and Abroad Transfer Principles of the relevant social media service providers, the relevant social media will be transferred to OZEL DEMIDERM POLIKLINIGI by the service provider and will be automatically processed and maintained by OZEL DEMIDERM POLIKLINIGI in accordance with its own Lighting Text and Privacy Policies that you are reading. In these cases, you agree to the Privacy Policy and the processing of your Personal Data and Sensitive Personal Data in accordance with the Lighting Text of the OZEL DEMIDERM POLIKLINIGI.
• You agree that OZEL DEMIDERM POLIKLINIGI will process your data in accordance with its KVK Disclosure Text and Privacy principles if you send a direct message to OZEL DEMIDERM POLIKLINIGI’s profile account, company officals and/or responsible manager doctor’s profile account, which you are already a user of, by accepting their own Privacy Policies and Foreign Transfer Policies, located on social media accounts whose servers are located abroad, you agree that OZEL DEMIDERM POLIKLINIGI will process your data in accordance with its KVK Disclosure Text and Privacy policies.

CASES WHERE YOUR DATA CAN BE PROCESSED WITHOUT SEEKING AN EXPLICIT CONSENT STATEMENT:

In accordance with Article 9/2/h of the GDPR and Article 6/3 of the KVKK:

• Your Health Data, which is considered to be Sensitive Personal Data, will be processed without your explicit consent by the responsible manager doctor, which is under the obligation to keep secrets in accordance with the Law, in order to carry out examination, medical diagnosis, treatment and care services.

In accordance with Article 6/1/b of the GDPR and Article 5/2/c of the KVKK:

• Your Personal Data will be processed by OZEL DEMIDERM POLIKLINIGI without your explicit consent in order to carry out your checks after the medical diagnosis and treatment processes, to contact you one-on-one, to manage the appointment processes.

In accordance with Article 6/1/f of the GDPR and Article 5/2 / f of the KVKK in accordance with our legitimate interests:

• Your Personal Data will be processed by OZEL DEMIDERM POLIKLINIGI without your explicit consent in order to carry out patient satisfaction and demand management.

Your Personal Data will be processed without your explicit consent in accordance with GDPR Article 6/1/c, KVKK Article 5/2/a and KVKK 5/2/ç in accordance with the legal obligations, in the following cases:

• Creation of a patient file.
• Preservation of information about your health data, which must be stored in accordance with the relevant legislation.
• Organizing invoices by checking your fee payments.
• Performance of tax payments.
• Performance of obligations in accordance with the Legislation of the Ministry of Health.
• Fulfillment of obligations in accordance with the Legislation on Medical Tourism.
• Ensuring your data security.
• Performance of legal obligations before the Judicial Authorities.
• Performance of administrative obligations before Administrative Institutions and Organizations.

TRANSFER OF YOUR PERSONAL DATA AND TO WHOM FOR WHAT PURPOSE IT WILL BE TRANSFERRED

Your Personal Data collected in accordance with the terms and purposes set out in Articles 5 and 6 of KVKK No. 6698 and the Terms of Personal Data Processing set out in Articles 6 and 9 of the GDPR, In accordance with Articles 8 and 9 of the KVKK and articles 45 and 49 of the GDPR, can be transferred to the 3rd persons and institutions mentioned below by providing all administrative and technical security measures in accordance with the legislation by signing the necessary confidentiality agreements for the purposes of execution and development of examination, medical diagnosis, treatment and care services, obtaining consultation services from other specialist physicians when necessary, fulfilling administrative obligations regarding health tourism legislation, planning transfer, accommodation and interpreter services of patients arriving within the framework of health tourism, communicating with patients, control appointments processes, planning and managing health services and financing, fulfilling the responsibilities arising from the legal relationship between the doctor and the patient, fulfilling financial, legal and administrative obligations, ensuring technical and commercial security and fulfilling public obligations, promoting the medical services offered by OZEL DEMIDERM POLIKLINIGI and to the extent that it is sufficient for the realization of the purpose.

In this context, your Personal Data processed by the OZEL DEMIDERM POLIKLINIGI will be transferred to:

• To other specialist physicians for consultation,
• To Insured Employees,
• To its suppliers:
• Financial Advisor, Tax and Finance Consultants and Auditors
• Legal Advisor
• Database (Server) Providers
• “Clinical Management Software Program” Service Providers
• Web Consultant
• Translators
• Data Protection Officer
• IT Consultant
• Tourism Agencies
• Overseas Promotion Consultant
• Support Management System (DYS) Officer
• Public Institutions and Organizations authorized within the framework of laws
• Judicial Authorities.

DURATION OF PERSONAL DATA PROCESSING

Your Personal Data will be stored by OZEL DEMIDERM POLIKLINIGI to the extent and for as long as it is legally obliged to store it. The documentation and storage obligations are due to local norms related to trade, tax and health legislation. The table shown below shows the storage periods of your Personal Data.

THE AGE LIMIT OF THE DATA SUBJECT WITHIN THE FRAMEWORK OF LEGISLATION

Within the scope of KVKK, patients / advisees may personally consent to the processing of their personal data, provided that they are at least 18 years of age. The consent of patients/clients who are below this age limit must be given by their legal representatives.

Within the scope of the GDPR, citizens of European Union countries and patients/advisees residing in European Union countries can give their consent to the processing of their personal data personally, provided that they are at least 16 years old or within the age limit stipulated in their country. The consent of patients/advisees under this age must be given by their legal representatives.

WITHDRAWAL OF CONSENT

If you give your consent to OZEL DEMIDERM POLIKLINIGI regarding the processing of your Personal Data, we will inform you that you can withdraw your consent at any time in accordance with Article 6/1/a of the GDPR and Article 5/1 of the KVKK for the purposes mentioned above. Your consent will be revoked if you submit your consent revocation statement to our contact address specified below again as indicated below.

THE RIGHTS OF DATA OWNERS IN ACCORDANCE WITH THE GDPR

As a Data Owner, your Personal Data is also protected in accordance with the GDPR. In cases where the GDPR is included in the jurisdiction (citizens of the European Union or residents of European Union countries), the rights of Data Owners are as follows:

• Right of Access (GDPR Article 15): The data owner has the right to confirm by applying to the OZEL DEMIDERM POLIKLINIGI whether the personal data relating to him is being processed, and to learn the details in Article 15 of the GDPR in case personal data is processed.
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• Right to Rectification (GDPR Article 16): The Data Owner has the right to have his personal data changed, which is under the responsibility of OZEL DEMIDERM POLIKLINIGI, always corrected by applying.
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• Right to Deletion (GDPR Article 17): The Data Owner has the right to request the deletion of his personal data held under the responsibility of OZEL DEMIDERM POLIKLINIGI. If the issues specified in Article 17 of GDPR occur, your personal data will be deleted by OZEL DEMIDERM POLIKLINIGI without delay.
• Right to Restriction of Processing (GDPR Article 18):
• If the Data Owners object to the up-to-datedness of their Personal Data, they have the right to request the restriction of the use of the data as the Data Owner, until the accuracy of the Personal Data is confirmed by the OZEL DEMIDERM POLIKLINIGI.
• In cases where the Data Owner requests the deletion of his Personal Data due to the illegality of the Personal Data processing activity, he has the right to request the restriction of the use of the data until the request is fulfilled.
• The Data Owner has the right to request the restriction of the use of his data in cases where his personal data is no longer needed for the purposes of processing by OZEL DEMIDERM POLIKLINIGI.
• In cases where the Data Subjects object to the processing in accordance with Article 21/1 of the GDPR, they have the right to request the restriction of the use of their data until it is verified whether the legitimate reasons for processing the data by the OZEL DEMIDERM POLIKLINIGI outweigh the legitimate reasons of the Data Owner.
• Right to Data Migration (GDPR Article 20): The Data Owner has the right to request the transfer of his Personal Data, which is held under the responsibility of OZEL DEMIDERM POLIKLINIGI, to another controller at any time, if technically possible. However, this right may be exercised when data processing is based on consent or when required by the contract.

• Right of Appeal (GDPR Article 21):

• The Data Owner has the right to object to the processing of Personal Data, including profiling within the scope of clauses (e) or (f) of Article 6(1) GDPR, on grounds relating to his particular situation. OZEL DEMIDERM POLIKLINIGI cannot process Personal Data unless it can show a strong legitimate reason that outweighs the interests, rights and freedoms of the Data Owner or the establishment, exercise or protection of a legal right.
• In cases where his Personal Data is processed for direct marketing purposes, the Data Owner always has the right to object to the processing of his personal data for this purpose, including profiling to the extent that it relates to such direct marketing.
• If the Data Owner objects to the processing of Personal Data for direct marketing purposes, the Personal Data will no longer be processed for such purposes.

THE RIGHTS OF DATA OWNERS IN ACCORDANCE WITH KVKK

The rights of natural persons whose Personal data has been processed in accordance with Article 11 of the KVKK are as follows:

• To find out if your personal data has been processed,
• To request information about your personal data if it has been processed,
• To find out the purpose of processing personal data and whether they are used for their intended purpose,
• To know the third parties to whom personal data is transferred at home or abroad,
• To request correction of personal data in case of incomplete or incorrect processing and to notify the third parties to whom the personal data has been transferred of the transaction made within this scope,
• To request the deletion or destruction of personal data in case of elimination of the reasons requiring its processing, although it has been processed in accordance with the provisions of KVKK and other relevant laws, and to request notification of the transaction made in this context to the third parties to whom the personal data has been transferred,
• To object to the emergence of a conclusion against the person himself by analyzing the processed data exclusively through automated systems,
• To request compensation of the loss in case of damage due to unlawful processing of personal data.

You can submit your written application personally by coming to the “Kültür Mah. Ali Çetinkaya Blv.  No:22 K:4 D:8 Alsancak/İzmir/Turkey” address on OZEL DEMIDERM POLIKLINIGI’s corporate websites, You can send it through a notary public or send it to info@demiderm.com.tr or “demiderm@hs01.kep.tr”  e-mail addresses by signing with a secure e-signature or send it by other methods specified in the KVKK, with wet signatures and documents to prove your identity, in case there are rights or requests that you want to use from your rights listed above, the articles on data owner rights contained in the GDPR and the rights specified in Article 11 of the KVKK that you clearly and clearly specify which rights you want to use. The presence of the following elements in your applications: first name, last name, signature, Republic of Turkey Identification Number / Passport Number / temporary Republic of Turkey Identification Number, residence or workplace address, e-mail address, telephone and fax number, is mandatory in accordance with the “Communique on the Procedures and Principles of Applying to the Data Controller”.

OZEL DEMIDERM POLIKLINIGI will finalize the request for free as soon as possible and no later than thirty (30) days, depending on the nature of the request. However, if the transaction also requires a cost, the fee will be charged at 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 OZEL DEMIDERM POLIKLINIGI, 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 OZEL DEMIDERM POLIKLINIGI in accordance with this Information Notice. 

You have right not to accept the Information Notice upon reading it.

DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ., reports as a “DATA CONTROLLER” within the scope of KVKK and as a “SUPERVISOR” within the scope of GDPR.

Best Regards.