ERA RADIOLOGICAL IMAGING SERVICES INC.
PRIVACY NOTICE REGARDING THE PROCESSING OF PERSONAL DATA OF PATIENTS AND RESEARCH PATIENTS
As Era Radyolojik Görüntüleme Hizmetleri Tic. A.Ş. (“Era Radyoloji” or the “Company“), we would like to inform you about our personal data processing activities in accordance with the Law No. 6698 on the Protection of Personal Data (the “Law“) and its secondary legislation.
1. Data Controller
As the data controller, Era Radyoloji may process your personal data for the purposes and within the scope described below, in compliance with the law and the principles of good faith and limited to the purposes of processing. Processing includes, but is not limited to, activities such as recording, storing, classifying, updating, and, where permitted by legislation or limited to the purposes for which the data is processed, transferring it to third parties.
2. Purpose and Transfer of Your Personal Data
In accordance with the fundamental principles set forth in the Law, your:
identity, signature, contact, financial, professional experience, customer transaction, examination request-related, and health data are processed for the following purposes:
- Ensuring compliance of activities with applicable legislation
- Conducting financial and accounting processes, including contractual processes
- Conducting storage and archiving activities
- Following up and conducting legal affairs solely in the event of disputes that may arise
Your identity, examination request-related information, and health data are processed for the following purposes:
- Obtaining technical support services in relation to technical problems that may occur in radiology devices
- Sharing information with contracted companies and laboratories with which we cooperate for obtaining pathology results
Your identity, contact, and transaction security data are processed for the following purposes:
- Conducting communication activities, including customer relations
- Conducting business activities, including patient admission, examination request entries, and service sales processes
Your identity, contact, customer transaction, and health data are processed for the following purposes:
- Conducting patient admission and examination request entries and service sales processes, including the conduct of medical research processes
- Conducting storage and archiving activities
Your personal data relating to identity and transaction security is processed for the following purposes:
- Conducting information security processes and storage and archiving activities
Your personal data relating to visual and audio recordings, limited to physical premises security and telephone recordings of the switchboard, is processed for the following purpose:
- Ensuring physical premises security
Your personal data is securely stored in physical or electronic environments for the period appropriate to the purposes of processing. Following the expiration of the retention periods determined in connection with the purposes, your personal data is destroyed in accordance with the procedures stipulated in the legislation and the methods specified in Era Radyoloji’s Data Retention and Destruction Policy. Within the scope of these activities, our Company acts in compliance with all obligations stipulated under the relevant legislation, particularly the Law concerning the protection of personal data.
For the purposes described above, your:
identity, health data, and examination request-related data are:
- Entered into the e-Nabız system and, within this scope, transferred to authorized public institutions and organizations
Your identity, signature, contact, financial, professional experience, health, and examination request-related data are:
- Transferred to natural persons or private-law legal entities, such as lawyers from whom we receive consultancy and support services, in order to conduct legal affairs processes where required due to our various legal obligations or where necessary for the establishment or protection of a right
- Transferred to relevant authorized public institutions and organizations for the purpose of providing information, including within the scope of audit processes
Your identity, contact, and health data are transferred, within the scope of conducting business processes, solely to physicians from whom external pathology services are obtained and to other external physicians requesting examinations, for the purpose of sending examination results.
Your identity, examination request-related information, and health data are:
- Transferred to companies from which we receive technical support services in relation to technical problems that may occur in radiology devices
- Transferred to contracted companies and laboratories with which we cooperate for obtaining pathology results
Finally, all of the above-mentioned data is transferred domestically to our suppliers from whom we receive support services in the field of information technologies, particularly for storage and archiving activities.
We would like to state that, within the scope of medical research studies conducted by research companies, the data of our research patients transferred to related companies is transferred in an anonymized manner for the purposes of conducting such research. Within this scope, your personal data is not transferred abroad.
3. Method and Legal Basis for Collecting Your Personal Data
Your personal data is collected through the data subject, electronic mail, portals through which documents are shared with you, telephone, our Company’s website, and other channels, primarily for the purposes described above, including the conduct of goods or services sales processes.
Within this scope, your personal data is processed in accordance with the principles stipulated in the Law and based on the following legal grounds: Article 5/2 (a), which provides that processing is “expressly stipulated by law”; Article 5/2 (c), which provides that processing is “necessary for the processing of personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of a contract”; Article 5/2 (ç), which provides that processing is “necessary for the data controller to fulfill its legal obligation”; Article 5/2 (e), which provides that processing is “necessary for the establishment, exercise, or protection of a right”; or Article 5/2 (f), which provides that processing is “necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”
Similarly, your special categories of personal data are processed where your explicit consent to processing has been obtained or where the processing conditions stipulated under Article 6/3 of the Law are met.
4. Your Rights
Pursuant to Article 11 of the Law, you have the following rights:
- To learn whether your personal data is processed by us.
- If your personal data has been processed, to request information regarding such processing.
- To learn the purpose of processing your personal data and whether it is used in accordance with its 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 has been processed incompletely or inaccurately.
- To request the destruction of your personal data under the conditions specified in the Law.
- In the event of correction or destruction, to request that such transactions be notified to third parties to whom the personal data has been transferred.
- To object if a result arises against you as a result of the analysis of your personal data exclusively through automated systems.
- To request compensation for damages if you suffer any damage due to the unlawful processing of your personal data.
In order to ensure that applications made by you to Era Radyoloji under this Article, which establishes the rights of the data subject, can be evaluated and resolved promptly, effectively, and comprehensively, you may complete the Data Subject Application Form available on our official website at https://eraradyoloji.com/EraRadyoloji-IlgiliKisiBasvuruFormu.docx and send it by registered mail with a wet signature to the address Mansuroğlu, Ankara Cd. Yanyolu No:47/A Mavi Plaza, 35535 Bayraklı/İzmir, together with a copy of your identification document on which the religion field is not present or, if present, has been redacted.
Upon receipt of your request and verification of your identity, the copy of your identification document submitted to us will be destroyed in accordance with the procedures stipulated in the applicable legislation.
Our Company will conclude your request as soon as possible and in any event within a maximum of thirty (30) days. Any costs that may arise during the examination and conclusion of your application will be invoiced to you in accordance with the fees set forth in the tariff determined by the Board.
* This Privacy Notice (“Notice“) was updated on [27.12.2021]. In the event of any changes to the Notice, its effective date and content will be updated.