Website Privacy Notice on the Processing of Personal Data

1. Data controller

Under the Turkish Personal Data Protection Law No. 6698 (“KVKK”), your personal data is processed by Op. Dr. Mehmet Durmuş Kurt (“Kurt Clinic”) in the capacity of data controller.

Address: Yeni Mahalle Mah. Abdülhalik Renda Cd. Hacı Nazım Apt. No:24/1, 34893 Pendik/İstanbul
Email: [email protected]
Phone: +90 555 081 71 65

This notice is addressed to persons who visit the Kurt Clinic website and who submit a contact or appointment request through the website. For health data processed in the course of examination, diagnosis, treatment and patient file processes, the separately provided patient privacy notice applies.

2. Personal Data Processed

Depending on how you use the website and how you contact us, the following data may be processed:

• Identity information: First name and last name.
• Contact information: Phone number, email address and your preferred contact channel.
• Request and communication information: Your appointment or callback request, your message and records of correspondence or conversations with you.
• Transaction security and technical data: IP address, connection time, browser and device information, server security logs, error logs and the cookie preference record.
• Analytics or marketing data: Data on website use and advertising interactions, only when the relevant tools have been enabled and you have given the required explicit consent.

Callback form: Only your full name and phone number are collected through the callback form on the website. This information is processed solely to respond to your callback request. To prevent misuse of the form, a one-way digest (hash) value derived from your IP address is kept on the server for no more than 24 hours; form data is not additionally stored in a database on the website.

The callback form on the website is not designed to collect health data. Please do not enter your diagnosis, test results, reports, prescriptions, photographs or detailed health information in this form. Health-related details should be shared through the appropriate and secure channels designated by the clinic.

3. Purposes and Legal Grounds for Processing Personal Data

Your personal data may be processed for the following purposes and on the basis of the processing conditions set out in the KVKK:

You may withdraw the consent you have given for processing based on explicit consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the date of withdrawal.

4. Transfer of Personal Data

Your personal data may be transferred to the following recipient groups, limited to the purposes above and to the extent necessary:

• suppliers providing hosting, server, email, form, maintenance, backup and information security services;
• authorized clinic staff and service providers involved in appointment and communication processes;
• professional advisors engaged for support in the fields of law, financial consultancy and information security;
• public institutions, judicial authorities and administrative authorities legally authorized to request it.

The full name and phone number you submit through the callback form are processed on the website’s server at the time of submission and forwarded to the clinic’s corporate email account via the Google Workspace email infrastructure. Since the servers of the Google Workspace service provider may be located outside Türkiye, this transmission is carried out within the framework of a transfer mechanism that complies with the KVKK’s provisions on cross-border transfers.

Analytics or advertising technologies from providers based abroad, such as Google Analytics, Google Ads or Meta Pixel, will be used only once the relevant tool has actually been enabled, the required cookie consent has been obtained and a transfer mechanism complying with the KVKK’s provisions on cross-border transfers has been established. While these tools are inactive, no analytics or advertising transfer takes place in this context.

5. Method of Collection

Your personal data is obtained through:

• your filling in the callback form on the website;
• your contacting us by phone, email or linked communication channels;
• the generation of server and security logs during your visit to the website;
• your consent to non-essential cookies,

directly from you, electronically and by fully or partially automated means.

6. Retention and Destruction

Your personal data is retained for as long as necessary for the purpose for which it is processed, limited to the limitation, evidentiary and retention periods set out in the applicable legislation. Once the processing conditions cease to exist, the data is deleted, destroyed or anonymized in accordance with the applicable legislation and Kurt Clinic’s retention and destruction procedures.

Personal data obtained through the callback form is kept for no more than 365 days from the date of the request, for the purposes of responding to the request, handling the communication and, where necessary, being able to demonstrate that the request was recorded. At the end of this period, it is deleted or destroyed, unless a separate legal obligation requires it to be kept for longer.

If your contact or appointment request leads to the establishment of a patient relationship, the related records may be subject to separate retention rules under health legislation and the rules on patient records.

If a visitor who used the callback form later goes on to have an examination, appointment or treatment, the resulting medical and patient records are kept separately from the form email and are retained in accordance with the retention periods set out in the applicable health legislation; the 365-day period stated for the form email does not apply to these records.

7. Your Rights under the KVKK

Under Article 11 of the KVKK, you have the right to:

• learn whether your personal data is being processed;
• request information about the processing if your data has been processed;
• learn the purpose of processing and whether your data is used in line with that purpose;
• know the third parties to whom your data is transferred within Türkiye or abroad;
• request the rectification of incomplete or inaccurately processed data;
• request the erasure or destruction of your data where the conditions set out in the Law are met;
• request that the rectification, erasure or destruction be notified to the third parties to whom the data has been transferred;
• object to an outcome detrimental to you arising from the analysis of your data exclusively through automated systems;
• claim compensation for damages if you suffer loss as a result of unlawful processing.

You have these rights.

8. How to Submit a Request

Your requests under the KVKK, marked “KVKK Başvurusu” (KVKK Application), may be submitted:

• in writing to Yeni Mahalle Mah. Abdülhalik Renda Cd. Hacı Nazım Apt. No:24/1, 34893 Pendik/İstanbul;
• using registered electronic mail (KEP), a secure electronic signature or a mobile signature;
• to [email protected] from the email address you have previously notified to Kurt Clinic and that is registered in our system; or
• by other methods accepted under the legislation.

You may use any of these methods.

The application must include your full name; your signature, if the application is in writing; for citizens of the Republic of Türkiye, the Turkish ID number; for foreign nationals, nationality and passport number or, if any, ID number; your address for notification purposes; your email/phone details, if any; and the subject of the request. Additional information may be requested to verify your identity and to prevent the disclosure of data to unauthorized persons.

Applications are concluded as soon as possible depending on the nature of the request, and within 30 days at the latest. If the process entails an additional cost, the fee schedule determined by the Turkish Personal Data Protection Board may apply.

9. Changes

This notice may be updated when personal data processing activities or the legislation change. The current version is published on the website.