Personal Data Protection (KVKK) Disclosure Text

## 1. Identity of the Data Controller

 

Pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK"), your personal data is processed by the following data controller:

 

**Dr. Sinan Akyürek**  

Teşvikiye Cd. No:19/13, Floor 6, Şişli, Istanbul, Turkey  

Email: drsinanakyurek@gmail.com  

Phone: +90 532 499 64 14

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## 2. Personal Data Processed and Purposes of Processing

 

The following personal data is collected and processed within the scope of the services provided by our clinic:

 

### 2.1 Identity and Contact Data

**Data:** Name, surname, phone number, email address, date of birth.  

**Purpose:** Creating patient records, managing appointment scheduling, providing pre- and post-treatment communication, and fulfilling legal reporting obligations.  

**Legal Basis:** Establishment or performance of a contract (KVKK Art. 5/2-c); fulfillment of legal obligations (KVKK Art. 5/2-ç).

 

### 2.2 Special Category Health Data

**Data:** Medical history, existing health conditions, medications, allergies, prior aesthetic procedures, treatment photographs, face analysis images, and any other health information shared voluntarily.  

**Purpose:** Conducting clinical assessment and face analysis; planning, performing, and documenting aesthetic medical treatments; ensuring patient safety; fulfilling Ministry of Health record-keeping obligations.  

**Legal Basis:** Your explicit consent (KVKK Art. 6/3); fulfillment of legal obligations in the field of healthcare (KVKK Art. 6/3).

 

### 2.3 Communication Data

**Data:** Messages sent via WhatsApp, email, or contact forms; content of consultations conducted digitally.  

**Purpose:** Responding to inquiries, confirming appointments, providing pre- and post-procedure information.  

**Legal Basis:** Explicit consent; legitimate interest.

 

### 2.4 Website Usage Data (Technical Data)

**Data:** IP address, browser type, device information, pages visited, session duration.  

**Purpose:** Ensuring website security and functionality; improving user experience; analytics.  

**Legal Basis:** Legitimate interest; explicit consent where required (for analytics/marketing cookies).

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## 3. Transfer of Personal Data

 

Your personal data may be transferred to the following parties, to the extent permitted by KVKK Articles 8 and 9, and only for the stated purposes:

 

- **Wix.com Ltd.:** Website hosting and infrastructure services (data processed under data processing agreements).

- **EntityMed:** AI skin analysis platform that processes facial photos and personal data (name, email, phone, skin goals) submitted via the face analysis simulator on this website. Data is processed under a data processing agreement and used solely to generate the skin analysis report delivered to the patient.

- **WhatsApp / Meta Platforms:** Communication services used with your consent.

- **Ministry of Health and authorized public institutions:** When required by law or regulatory authority.

- **Courts and enforcement authorities:** When required by a court order or legal proceeding.

- **Referring physicians or specialist clinics:** Only with your explicit written consent, when medically necessary.

 

Your personal data is not sold, rented, or shared with any commercial third party for marketing purposes without your explicit consent.

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## 4. Method and Legal Basis of Data Collection

 

Your personal data is collected through the following channels:

 

- In-clinic registration and intake forms (physical)

- Digital consent forms

- Website contact and face analysis forms

- WhatsApp and email communications

- Clinical examination and treatment records

 

Data is processed on the following legal grounds under KVKK Article 5 and Article 6:

 

- Your explicit consent

- Establishment and performance of a contract

- Fulfillment of legal obligations

- Protection of vital interests

- Legitimate interests of the data controller (where not overridden by your rights)

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## 5. Your Rights as a Data Subject

 

Pursuant to KVKK Article 11, you have the following rights with respect to your personal data:

 

a) To learn whether your personal data is being processed,  

b) To request information about the processing if it has occurred,  

c) To learn the purpose of processing and whether data is used in accordance with that purpose,  

d) To know the third parties to whom your data has been transferred, domestically or abroad,  

e) To request correction of incomplete or inaccurate data,  

f) To request deletion or destruction of your data under the conditions set out in KVKK Article 7,  

g) To request that correction and deletion operations be notified to third parties to whom data has been transferred,  

h) To object to outcomes arising from analysis of your data exclusively by automated means that are detrimental to you,  

i) To claim compensation for damages suffered due to unlawful processing of your data.

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## 6. How to Exercise Your Rights

 

To exercise any of the rights listed above, you may submit a written application to our clinic. Your application must include your name, surname, Turkish ID number (or passport number for foreign nationals), contact information, and the right you wish to exercise.

 

**Application methods:**

 

• **In person:** Teşvikiye Cd. No:19/13, Floor 6, Şişli, Istanbul (with valid ID)

• **By email:** drsinanakyurek@gmail.com (signed with a secure electronic signature, or submitted with a copy of ID)

• **By registered post (KEP or notarized):** To the address above

 

We will respond to your application within **30 (thirty) days** at the latest. Applications are free of charge. However, if the response requires significant effort, a fee may be charged in accordance with the tariff set by the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

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## 7. Data Retention

 

Your personal data is retained for the minimum periods required by applicable Turkish healthcare regulations. In accordance with the Private Health Facilities Regulation, patient records are kept for a minimum of **5 (five) years** from the date of last treatment. At the end of the retention period, data is securely destroyed in line with the clinic's data destruction policy.

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## 8. Data Security

 

Your data, especially health data and treatment photographs, is stored securely and accessible only to authorized clinical personnel. We take all necessary technical and administrative measures to prevent unauthorized access, disclosure, alteration, loss, or destruction of your personal data.

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## 9. Explicit Consent

 

Where your explicit consent is required for the processing of your personal data — particularly for special category health data, digital communications, and marketing activities — such consent is obtained separately and in advance, either via a signed consent form at the clinic or through a digital consent mechanism on the website. You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

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## 10. Contact

 

**Dr. Sinan Akyürek Medical Aesthetics Clinic**  

Teşvikiye Cd. No:19/13, Floor 6, Şişli, Istanbul  

drsinanakyurek@gmail.com  

+90 532 499 64 14