DENTSO GDPR

As DENTSO AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ ANONİM ŞİRKETİ (“DENTSO” or the “Company”), acting as the data controller, we process your personal data within the scope of the Law No. 6698 on the Protection of Personal Data (“GDPR” or the “Law”) and the relevant legislation. We also take the technical and administrative measures stipulated in the GDPR, the secondary legislation enacted under the GDPR, the binding decisions of the Personal Data Protection Board, and other applicable legislation, and we make every effort to protect the data we process.

With this text, as the data controller, we aim to inform you in detail about the processing, storage, and transfer of your personal data processed in connection with your specific activities as our:

• Website Visitors,
• Patients,
• Job Applicants,
• Suppliers’ Authorized Representatives, and
• Suppliers’ Employees

I. PERSONAL DATA WE PROCESS, METHODS OF COLLECTION, AND PURPOSES OF PROCESSING

A. WEBSITE VISITORS

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As DENTSO, we collect the personal data of our Website visitors, wholly or partially by automated means, through:

• Your visit to the Website,
• Cookies used on the Website,
• Data you share with us via the Chat section on the Website if you contact us through it,
• Creating an appointment via the “Make an Appointment” tab on the Website,
• Contacting us through the “E-Examination” and “Contact” tabs on the Website

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data obtained by the methods explained above are as follows:

PERSONAL DATA CATEGORIES	DATA TYPES
Identity	Name, surname
Contact	Phone number
Transaction Security Data	Traffic data
Health	Appointment date and time, information on the procedure to be performed, physician information, complaint/request information
Other Information	Data contained in the message content

The personal data listed in the table are processed for the following purposes:

• Creating your appointment based on the procedure to be performed and the preferred physician,
• Contacting you regarding your appointment and sending reminders,
• Providing remote oral and dental health services without visiting our hospitals,
• Responding to your complaints and requests regarding our services and contacting you in this regard,
• Fulfilling our obligation to keep traffic records as explicitly provided under the Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications and the relevant legislation,
• Ensuring a more effective, faster, and easier use of the Website,
• Carrying out the necessary work so that you can benefit from our services and activities,
• Taking all necessary technical and administrative measures within the scope of data security

Your personal data are collected by DENTSO based on the legal grounds set forth in Article 5 of the GDPR, namely: being necessary for the establishment and performance of the relevant contract; being explicitly stipulated by law; being necessary for DENTSO to fulfill its legal obligations; and, provided that it does not harm the fundamental rights and freedoms of the data subject, being necessary for the legitimate interests of DENTSO.

B. PATIENTS

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As the data controller, we collect the personal data of our patients, wholly or partially by automated means or by non-automated means provided that they are part of a data recording system, through:

• Complaints and requests submitted to the Company by our patients via phone, e-mail, or other means,
• Documents filled out regarding the procedures performed by our patients within our hospitals,
• Printed forms, records, and necessary information and documents that must be completed due to legal regulations and the Company’s legal obligations,
• Security cameras located in various areas within our hospitals

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data of DENTSO patients that are processed are categorized and listed in the table below:

PERSONAL DATA CATEGORIES	DATA TYPES
Identity Data	Name-surname, gender, date of birth, signature, Turkish ID number, age
Contact Data	Address, e-mail address, phone number
Customer Transaction Data	Invoice information
Health Data	Anamnesis information, COVID-19 triage information, physician information, physician’s suitability opinion regarding the intervention, consent regarding the intervention, radiographic imaging, appointment information, complaint information, treatment plan, diagnosis information, medical intervention information
Physical Space Security	Security camera recordings

The personal data of the product or service recipient listed in the table are processed for the following purposes:

• Providing you with health services in the field of oral and dental health,
• Planning your treatment process in line with your complaints and personal health condition,
• Managing appointment processes,
• Contacting you regarding the service you received,
• Charging for the health service you received, preparing a payment plan, and collecting payment,
• Carrying out invoicing processes in accordance with the relevant legislation for the service you received,
• Fulfilling our legal obligations and exercising our rights arising from the applicable legislation,
• Ensuring physical space security,
• Ensuring the security of movable property and resources,
• Ensuring the security of data controller operations

C. JOB APPLICANTS

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As the data controller, we collect the personal data of our job applicants by automated means or by non-automated means provided that they are part of a data recording system, through:

• Resumes submitted to DENTSO by the job applicant directly or via platforms such as kariyer.net, İŞKUR, etc.,
• Job Application Form,
• Security cameras located in various areas within our hospitals

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data of DENTSO job applicants that are processed are categorized and listed in the table below:

PERSONAL DATA CATEGORIES	DATA TYPES
Identity Data	Name-surname, date of birth, signature
Contact Data	E-mail address, district of residence, phone number
Personnel Data	Military service status, position applied for, salary expectation
Professional Experience Data	Computer skills, education information, hobbies, work experience, courses/seminars attended, resume, reference information, foreign language proficiency
Visual and Audio Records	Photograph
Physical Space Security	Security camera recordings
Health	Smoking status

The personal data of job applicants listed in the table are processed for the following purposes:

• Managing job application, selection, and placement processes; assessing your suitability for the position; identifying your distinguishing qualifications,
• Enabling you to be distinguished from other candidates by your name, surname, and photograph,
• Planning HR processes by evaluating the department you wish to work in,
• Evaluating your suitability for the position to ensure Company business continuity,
• Planning HR activities over time within recruitment processes,
• Determining whether you meet the health conditions required for the job,
• Ensuring and auditing the security of recruitment activities by verifying the accuracy of the information you provide with your referees,
• Contacting you to share application results,
• Ensuring the security of movable property and resources,
• Ensuring the security of data controller operations

For the information contained in resumes you submit to us by any means, it is deemed that you have given explicit consent for the processing of such data by us. Please do not share resumes that include data you do not want our Company to process.

Please do not share special categories of personal data in your resumes, such as your health data, membership in associations, foundations or unions, or your religious or sectarian information.

With respect to the personal data regarding your referees included in your resumes or the Job Application Form you completed, it is deemed that the obligation to inform has been fulfilled by the job applicant. We kindly ask you to inform these persons in advance regarding the personal data you share about your referees.

D. SUPPLIERS’ AUTHORIZED REPRESENTATIVES

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As DENTSO DENTAL, we collect the personal data of our Suppliers’ authorized representatives through documents sent to the Company via e-mail, current account forms, copies of signature circulars, copies of tax certificates, copies of records in the Trade Registry Gazette, contracts we sign with you and their annexes, and security cameras located in various areas within our hospitals.

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data obtained by the methods explained above are as follows:

PERSONAL DATA CATEGORIES	DATA TYPES
Identity	Name, surname, signature, Turkish ID number
Contact	E-mail address, phone number
Legal Transaction	Signature circulars, power of attorney
Finance	Bank account information
Physical Space Security	Security camera recordings

The personal data listed in the table are processed for the following purposes:

• Procuring goods and/or services to meet our Company’s needs,
• Managing the processes related to the establishment and performance of contracts and conducting follow-ups and confirmations to ensure proper performance of the contract,
• Making necessary reminders and carrying out instructions to ensure proper performance of the contract,
• Establishing communications with you regarding contract and goods or service procurement processes,
• Distinguishing you by name and surname from other supplier representatives,
• Managing invoicing and financial obligation processes in accordance with the relevant legislation,
• Managing in-house audit and verification processes,
• Ensuring physical space security,
• Ensuring the security of movable property and resources,
• Ensuring the security of data controller operations

E. SUPPLIERS’ EMPLOYEES

1. METHOD OF COLLECTING YOUR PERSONAL DATA

As DENTSO, we collect the personal data of our Suppliers’ employees through correspondence with supplier representatives and employees, current account records, contracts and their annexes, and security cameras located in various areas within our hospitals.

2. PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data obtained by the methods explained above are as follows:

PERSONAL DATA CATEGORIES	DATA TYPES
Identity	Name, surname, signature
Contact	E-mail address, phone number
Personnel	Duty/title information
Physical Space Security	Security camera recordings

The personal data listed in the table are processed for the following purposes:

• Conducting follow-ups and confirmations to ensure proper performance of the contract,
• Making necessary reminders and carrying out instructions to ensure proper performance of the contract,
• Establishing communications with you regarding contract and goods or service procurement processes,
• Distinguishing you by name and surname from other supplier employees,
• Managing invoicing and financial obligation processes in accordance with the relevant legislation,
• Ensuring physical space security,
• Ensuring the security of movable property and resources,
• Ensuring the security of data controller operations

II. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Your personal data are collected by DENTSO based on the legal grounds set forth in Article 5 of the GDPR, namely: being explicitly stipulated by law; being necessary for the Company to fulfill its legal obligations; being necessary for the processing of personal data of the parties to a contract, directly related to the establishment or performance of the sales contract; being necessary for the establishment, exercise, or protection of a right; and, provided that it does not harm the fundamental rights and freedoms of the data subject, being necessary for the legitimate interests of DENTSO.

III. RECIPIENTS TO WHOM YOUR PERSONAL DATA ARE TRANSFERRED AND PURPOSES OF TRANSFER

Your personal data may be transferred to:

1. The relevant group company, depending on the DENTSO hospital at which Job Applicants wish to work, Patients have made an appointment, or Suppliers provide products and/or services,
2. Laboratories from which we receive services to meet needs such as implants depending on the scope of our patients’ treatments,
3. Certified public accountants, lawyers, and other third parties from whom we receive consultancy services so that we can conduct our business processes in compliance with the law and other legitimate interests and to exercise our right of defense in a possible litigation process,
4. Regulatory and supervisory authorities and relevant official bodies such as courts and enforcement offices, and other public institutions or organizations authorized to request your personal data, provided that it is lawful and proper, in order to fulfill our legal obligations,
5. Your proxies and representatives authorized by you, in order to fulfill your requests

Transfers are made within the scope of the personal data processing conditions and purposes specified in Article 8 of the GDPR.

IV. PERSONAL DATA TRANSFERRED ABROAD

As DENTSO, we do not transfer your personal data abroad. However, if you contact us via channels such as e-mail or WhatsApp, your personal data shared in this way may be transferred abroad by you due to the servers of these applications being located abroad.

If you do not want your personal data to be transferred abroad, you can contact us in person at our Branches or via our phone number +90 212 669 33 33.

V. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Regarding your personal data, you have the right to:

• Learn whether your personal data are processed,
• Request information if your personal data have been processed,
• Learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
• Know the third parties to whom your personal data are transferred at home or abroad,
• Request the correction of your personal data if they are incomplete or incorrectly processed,
• Request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the GDPR,
• Request that the transactions carried out pursuant to subparagraphs (d) and (e) be notified to third parties to whom your personal data have been transferred,
• Object to a result against you arising from the analysis of your processed data exclusively through automated systems,
• Request compensation for your damages in case you suffer damage due to the unlawful processing of your personal data

Within the scope of the rights specified above, you may submit your requests in accordance with the “Communiqué on the Principles and Procedures for the Request to Data Controller” by applying in person or via notary, or by using your registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the e-mail address previously notified by you to the Company and registered in the Company’s system.

Your application will be answered in accordance with the relevant provisions set forth in the GDPR, and DENTSO may request certain verifying information from you to confirm that the applicant is indeed the correct person; such information will be requested solely to determine the real data owner and to share the application results with the correct person.

VI. CONTACT INFORMATION

DENTSO AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ ANONİM ŞİRKETİ

E-mail        : [email protected]

Contact Link : https://dentso.com.tr/

Address       : Göktürk M. Mahallesi Göktürk Cad. No:44/A 34077 Göktürk / İstanbul