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HEALTH TOURIST PATIENT/ CLIENT EXPLICIT CONSENT
I read and understood the "Clarification Text on the Processing of Personal Data" submitted to me by APEKS AĞIZ DİŞ SAĞLIĞI HİZMETLERİ TİC. LTD. ŞTİ.’nin (“DENTIST KUSADASI” ) and "all my rights" regarding the legislation clearly stated in the text, verbally and in writing, in a language that I can understand, and by DENTIST KUSADASI officials and Dt. Elçin KÖLE I was informed by answering my questions. In line with the matters explained in the clarification text and the provisions in the KVKK and GDPR, I will provide the organization of my contact information from my Personal Data that I have given to DENTIST KUSADASI, in order to carry out my examination, preventive medicine, medical diagnosis, treatment, care and control services, to improve the medical treatment practice applied to me, to remind my appointment dates for continuous treatments and to be informed about the innovations in medical treatment and practices, I consent that they are PROCESSED by DENTIST KUSADASI for the purposes stated above, That they contact me for the fulfilment of the services offered by DENTIST KUSADASI, to be informed about the innovations, campaigns and promotions regarding the services offered, and to SEND ME AN SMS, E-MAIL, WHATSAPP MESSAGE, AND ESTABLISH MOBILE COMMUNICATIONS via my contact data for celebration and congratulation on special days or I AGREE TO BE REACHED TO ME THROUGH SERVICE PROVIDERS.
CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA
DENTIST KUSADASI
CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA
This clarification text is prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“ KVKK ”) in Turkish Law and the European Union General Data Protection Regulation (“ GDPR ”) by APEKS AĞIZ DIŞ SAĞLIĞI HIZMETLERI TIC. LTD. ŞTI.’ne (“ DENTIST KUSADASI ”) for the purpose of clarification of the data owners about the procedures and principles regarding the processing of Personal Data of patients/clients.
One of the primary goals of DENTIST KUSADASI is to ensure the security of the Personal Data of the health tourist patients/clients. Therefore, DENTIST KUSADASI takes the necessary security measures in accordance with the current legislation in order to securely process the Personal Data of the health tourist patients/clients and to prevent any unlawful access or leakage to this data.
DATA CONTROLLER
Your Personal Data will be processed within the scope of KVKK No. 6698 by APEKS AĞIZ DİŞ SAĞLIĞI HİZMETLERİ TİC. LTD. ŞTİ. operating at the address “Bayraklıdere Mah. Turgut Özal Bulv. Platin Konakları No: 88 Kuşadası/Aydın/Turkey”. APEKS AĞIZ DIŞ SAĞLIĞI HIZMETLERI TIC. LTD. ŞTI. with Civil Registry System No. 0071006922900017 and it will be considered as " DATA CONTROLLER " within the scope of KVKK and as “ DATA RESPONSIBLE ” within the scope of GDPR.
Within the scope of GDPR, DENTIST KUSADASI has made an agreement with a law firm with Personal Data Protection Expertise as "Data Protection Officer", and the Compliance Process on the Protection of Personal Data within the scope of KVKK and GDPR was carried out under the consultancy and guidance of the expert law firm.
YOUR PERSONAL DATA TO BE PROCESSED
Your Personal Data stated below will be processed by DENTIST KUSADASI in accordance with the basic principles stipulated by KVKK Article 4 and GDPR Article 5, in line with the Personal Data Processing Conditions and Purposes specified in KVKK Articles 5 and 6 and GDPR Articles 6 and 9 by taking all kinds of technical and administrative measures foreseen in the legislation in order to ensure data security, in an accurate and up-to-date manner, in accordance with the law, in connection with the purpose of processing, in a limited and measured manner, taking into account the principles of fairness and transparency, within the scope of the purposes that take place.
1- 1- YOUR IDENTIFICATION INFORMATION: Your name, surname, your T.R. Identity Number and/or Passport Number and/or Temporary T.C. Your Identity Number, identity information, passport information, place and date of birth, marital status, gender, occupation, signature and other identification data that can identify you.
2- YOUR CONTACT INFORMATION: Your address (residence/workplace), your phone number (your home/workplace fixed and/or mobile phone numbers), e-mail address, IP address, social media accounts and other contact data.
3-YOUR HEALTH INFORMATION: Your blood type, laboratory and imaging results, tests, allergies, chronic diseases, venereal diseases, infectious diseases, data on previous surgeries/operations, medications you constantly use, information on Covid-19 disease, medical treatments, prescription information, skin your analysis data, body measurement analysis data, your unhealthy habits and other health data required for the treatment and applications you request to be applied to you by coming to Turkey as a health tourist.
4- YOUR VOICE RECORDING WITH YOUR PHOTOS AND VIDEO IMAGES: Your image and audio recording data in the photographs and/or videos recorded before, during and/or after the medical procedure.
5-FINANCIAL INFORMATION: Your bank account number, IBAN number, credit card information, billing and billing information and other financial data.
6-YOUR TRANSFER AND ACCOMMADATION INFORMATION: Since you are a Health Tourist coming within the scope of International Health Tourism, your transfer information, flight ticket and return information, hotel accommodation information .
FOR WHAT PURPOSE YOUR PERSONAL DATA ARE PROCESSED
Your Personal Data are processed by DENTIST KUSADASI in accordance with KVKK and GDPR in order to be able to understand and manage, to fulfill financial and administrative obligations, to provide technical and commercial security and to fulfill public obligations to be able to communicate with you one-to-one, to fulfill legal and contractual obligations, to keep the information about your personal data that must be kept in accordance with the relevant legislation, within the specified periods, to organize the health service you want to receive in Turkey, to provide the health care service to be applied to you and/or or to make a doctor's planning, to receive consultation services from other relevant specialist physicians when necessary in order to plan your treatment correctly, to fulfill legal obligations in accordance with the legislation within the scope of health tourism, to plan your transfer, accommodation and interpreter services within the scope of health tourism, to perform satisfaction and demand management regarding the service you receive, to be able to announce innovations in medical treatment and practices, to inform third parties about the applied medical procedure, to plan health services and financing:
- Your Identity Data; It will be processed in order to plan and organize your examination, preventive medicine, medical diagnosis, treatment and care services, to perform the satisfaction and demand management of the service received, to plan your transfer, accommodation and interpreter services within the framework of Health Tourism.
- Your Contact Information; It will be processed in order to be able to communicate with you in order to provide the organization and planning of the health service you will receive in Turkey, to plan your transfer, accommodation and interpreter services, and also for the purpose of promoting and announcing the innovations regarding the medical treatments and practices offered in Turkey, provided that you give your express consent, and to congratulate and celebrate on special occasions.
- Your Health Information; It will be processed in order to fulfill the legal obligations within the scope of the current Health Tourism Legislation to organize the health service you want to receive in Turkey, to plan the health institution and/or doctor that will fulfill the health service to be provided to you, to receive consultation services from other relevant specialist physicians when necessary in order to plan your treatment correctly, to fulfill legal obligations in accordance with the legislation within the scope of health tourism.
- Your Photo, Video and Audio Recording Information; With your explicit consent, your personal data may be processed for the purpose of announcing innovations, advertising and promotion to be able to plan the health institution and/or doctor that will provide the health service to be provided to you, to plan and manage the financing of the health care services you request, to receive consultation services from other relevant specialist physicians when necessary in order to plan your treatment correctly, to introduce the health services offered in Turkey to third parties.
- Your Financial Data; It will be processed for the purpose of issuing invoices by controlling your fee payments and refunding in case of any excess fees.
- Your Transfer and Accommodation Information; It will be processed in order to plan your transfer and accommodation services within the framework of health tourism.
Your above-mentioned personal data will be processed by obtaining your explicit consent when necessary, in line with the above-mentioned purposes and legislation. If you do not provide your relevant personal data, the legal and contractual obligations imposed on DENTIST KUSADASI, which will serve you, will not be fulfilled properly and the organization and planning of the health service you want to receive in Turkey will not be carried out successfully.
METHOD OF COLLECTION OF PERSONAL DATA
Your Personal Data and Sensitive Personal Date will be collected as follows depending on the service offered by DENTIST KUSADASI to you and will be processed in accordance with KVKK and GDPR in order for DENTIST KUSADASI to fully and properly fulfill its contractual and legal obligations;
- By coming to DENTIST KUSADASI for examination and treatment, through your health reports, laboratory and imaging results, analyzes, health reports and health data statements and examination findings, which you submit for medical evaluation regarding the treatment to be applied to you,
- By filling in the "Patient Information and Consent Form" regarding the treatment to be applied by the DENTIST KUSADASI,
- Through the contact form you filled in on the corporate website of DENTIST KUSADASI, www.dentistkusadasi.com ,
- By e-mails you send to the corporate e-mail address (info dentistkusadasi.com) of the DENTIST KUSADASI,
- By means of photo/video records to be recorded in order to observe your treatment before, after and/or during the medical procedure applied/to be applied to you by DENTIST KUSADASI,
- At your request and where necessary; In order to carry out your online diagnosis and controls by DENTIST KUSADASI, remote connection application service providers (whatsapp/zoom.us/facetime/Skype/messanger) from which you receive service by accepting their Privacy Policy and International Transfer Policy. /google/instagram/facebook/beep/telegram/clubhouse etc.) to the DENTIST KUSADASI and/or to the responsible manager Dt. , KÖLE through your written/audio/visual (photo and/or video recording) messages you send and your online audio/video calls that you set up through these applications,
- DENTIST KUSADASI, which is available on social media accounts (instagram/youtube/ facebook/ twitter/linkedin/clubhouse etc.) whose servers you are already a user by accepting their Privacy Policy and International Transfer Policy' neither and/or the responsible manager Dt. Elçin KÖLE by sending a direct message to the profile account of her and/or commenting on her posts,
- By accepting their Privacy Policy and International Transfer Policy, the responsible manager Dt. Eçin KÖLE through the information you transmit by allowing it to be automatically processed through panels such as "contact us" or "get information" in the promotions and advertisements of DENTIST KUSADASI,
- In case you want to join the existing wireless internet network (wi-fi) within the body of DENTIST KUSADASI as a guest user, through log-recording devices (firewall) used within the scope of technical measures taken in accordance with the legislation,
- Within the scope of the legitimate interest of DENTIST KUSADASI, through security cameras with sound recording feature, which are under closed circuit recording for the purpose of ensuring workplace safety.
PURPOSE, METHOD AND LEGAL REASON
OF PROCESSING YOUR PERSONAL DATA
Your Personal Data, which is processed completely or partially automatically or by non-automatic means provided that it is a part of any data recording system, is authorized by DENTIST KUSADASI as a "DATA PROCESSOR", verbal, written, camera and photographic recordings, as well as the necessary technical and administrative security measures, by keeping the physical and electronic record, and in cases where the relevant provisions of the KVKK and GDPR are foreseen, it can also be processed with your explicit consent.
SITUATIONS REQUIRED TO GET YOUR EXPLICIT CONSENT STATEMENT
Pursuant to article 6/1/a of GDPR and article 5/1 of KVKK, your Personal Data can only be processed by obtaining your explicit consent in the following cases;
- Sending sms messages and/or e-mails and mobile communication to you for the purpose of announcing the innovations, campaigns and advertisements regarding the services provided by DENTIST KUSADASI will only be possible with your explicit consent
- Before the medical procedure, during the medical procedure and / or after the medical procedure, your photographs and / or video recordings taken in order to observe the development of the treatment are sent to the DENTIST KUSADASI and / or on social media accounts of the responsible manager Dt. ELÇİN KÖLE (instagram, youtube, facebook, twitter, linkedin etc.) and corporate websites will only be possible with your explicit consent.
- Since sharing your data through service providers whose servers are located abroad will be considered as "transfer abroad" and there is an "explicit consent condition" for transfer abroad, your explicit consent will be obtained in such cases. However, since there will be no international transfer by DENTIST KUSADASI in the following cases, YOUR EXPRESS CONSENT WILL NOT BE REQUESTED, AND YOUR EXPRESS CONSENT WILL BE RECEIVED BY THE SERVICE PROVIDER YOU ARE THE USER OF;
- By accepting its Confidentiality Agreement and International Transfer Policy, by using service providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram /facebook/telegram/clubhouse etc.) of which you are a current user and whose servers are located abroad, DENTIST KUSADASI and/or if you send a written/audio message and/or photo/video recording or make an audio/video call to the responsible manager Dt. Elçin KÖLE or request remote examination/diagnosis service by contacting yourself in this way; By accepting the policies of the aforementioned applications, you accept the processing of your Personal Data and Sensitive Personal Data that you share with DENTIST KUSADASI through these applications, in accordance with the KVK Clarification Text and Confidentiality Principles that will be sent to you through the application of DENTIST KUSADASI. You give your explicit consent to the relevant service provider for the transfer of your data abroad, in accordance with the policies you have previously accepted, of these applications whose servers are located abroad.
- In cases where you request to be contacted via e-mail service providers (Hotmail, gmail, yahoo, etc.) whose servers you are currently using abroad, by accepting their Privacy Policy and International Transfer Policy; You have accepted that DENTIST KUSADASI will process your Personal Data and Sensitive Personal Data shared in messages in accordance with its own KVK Clarification Text and Privacy principles, and in accordance with the previously accepted policies of these service providers whose servers are abroad, you can send an e-mail to transfer your data abroad. You give express consent to your service provider.
- DENTIST KUSADASI and/or responsible manager Dt. In cases where you apply to ELÇİN KÖLE's advertisements and promotions published on social media service providers (facebook, instagram, google, whatsapp, etc.) whose servers are located abroad; Your data, which you allow to be automatically processed and transferred abroad by accepting the Privacy and International Transfer Policy of the relevant social media service providers, will be transferred to DENTIST KUSADASI by the relevant social media service provider and it will be processed and preserved by the DENTIST KUSADASI in accordance with its own Illumination Text and Privacy Policy that you are reading. In these cases; You agree to the Clarification Text and Privacy Principles of DENTIST KUSADASI, and the processing of your Personal Data and SensitivePersonal Data in this direction.
- To the DENTIST KUSADASI, whose servers are located abroad (instagram, youtube, facebook, twitter, linkedin, etc.) by accepting their Privacy Policy and International Transfer Policy and/or if you send a direct message to the profile account of Dt. ELÇİN KÖLE; You agree that DENTIST KUSADASI processes your data in accordance with its own KVK Clarification Text and Privacy principles
SITUATIONS WHERE YOUR DATA MAY BE PROCESSED WITHOUT LOOKING FOR A STATEMENT OF EXPLICIT CONSENT:
According to GDPR Article 6/1/b and KVKK Article 6/3;
- Your Health Data, which is considered as Sensitive Personal Data, will be processed without your explicit consent by Dentist ELÇİN KÖLE, who is under the obligation to keep confidential as required by law , in order to carry out examination, medical diagnosis, treatment and care services.
According to GDPR Article 6/1/b and KVKK Article 5/2/c;
- Your Personal Data will be processed by DENTIST KUSADASI, without your explicit consent, in order to be able to carry out your checks after the medical diagnosis and treatment processes, to communicate with you one-to-one, and to manage the appointment processes.
Based on our legitimate interests in accordance with GDPR article 6/1/f and KVKK article 5/2/f;
- Your personal data will be processed by DENTIST KUSADASI without your explicit consent in order to realize customer satisfaction and demand management.
Based on legal obligations pursuant to GDPR article 6/1/c, KVKK article 5/2/a and KVKK 5/2/ç, your Personal Data will be processed without your explicit consent in the following cases;
- Patient file creation.
- Preservation of information about your health data, which must be kept in accordance with the relevant legislation.
- Issuing invoices by controlling your wage payments.
- Execution of tax payments.
- Fulfillment of obligations pursuant to Ministry of Health Legislation.
- Fulfillment of obligations pursuant to Health Tourism Legislation.
- Ensuring your data security.
- Fulfillment of legal obligations before the Judicial Authorities.
- Fulfillment of administrative obligations before Administrative Institutions and Organizations.
TRANSFERRING YOUR PERSONAL DATA AND TO WHOM IT WILL BE TRANSFERRED TO
Your Personal Data collected in accordance with the conditions and purposes within the scope of Personal Data Processing Conditions specified in Articles 5 and 6 of the KVKK No. 6698 and Articles 6 and 9 of the GDPR; will be transferred by DENTIST KUSADASI, in accordance with Articles 8 and 9 of the KVKK and Articles 45 and 49 of the GDPR in order to fulfill legal and contractual obligations, to organize the health service you want to receive in Turkey, to plan the health institution and/or doctor that will provide the health service to be provided to you, to receive consultation services from other relevant specialist physicians when necessary in order to plan your treatment correctly, to fulfill legal obligations in accordance with the legislation, to plan your transfer, accommodation and interpreter services within the framework of health tourism, to inform third parties about the service you receive, to carry out promotional and marketing activities, to plan and manage health services and financing, to fulfill financial and administrative obligations, to fulfill technical and administrative obligations, to ensure commercial security and fulfill public obligations, to the extent that it is sufficient for the realization of the purpose, by signing the necessary confidentiality agreements, by providing all administrative and technical security measures in accordance with the legislation, and it will be able to transfer it to the 3rd persons and institutions specified below. In this context, your Personal Data processed by DENTIST KUSADASIwill be transferred to the followings;
- To other specialist dentists for consultation,
- To Insured Employees,
- To its suppliers,
- Financial Advisor, Tax and Finance Consultants and Auditors
- Legal Advisor
- Database (Server) Providers
- “Clinical Management Software System” Service Provider
- Translators
- Web Consultant
- Overseas Promotion Consultant
- Data Protection Officer
- IT Consultant
- Support Management System (DYS) Officer
- Laboratory Centers
- Tourism Agencies
- To Insurance Companies,
- To Public Institutions and Organizations authorized within the framework of laws
- Can be transferred to Judicial Authorities
PERSONAL DATA PROCESSING PERIOD
Your Personal Data will be kept by DENTIST KUSADASI to the extent and as long as it is legally obliged to keep it. Documentation and custody obligations derive from local norms regarding trade, tax and health legislation. The following table contains the retention periods for your Personal Data.
|
Kişisel Verileriniz |
Saklama Süreleri |
|
Your Identity Information |
20 Years After the End of the Service Provided to the Service Receiver |
|
Your Contact Information |
20 Years After the End of the Service Provided to the Service Receiver |
|
Your Health Information |
20 Years After the End of the Service Provided to the Service Receiver |
|
Your Photo and Video Information |
20 Years After the End of the Service Provided to the Service Receiver |
|
Your Financial Information |
5 Years After the End of the Service Provided to the Service Receive |
DATA OWNER AGE LIMIT IN THE FRAMEWORK OF LEGISLATION
Within the scope of KVKK, health tourist advisers will be able to personally give consent for the processing of their personal data, provided that they are at least 18 years old. The consent of the counselees who are below this age limit must be given by their legal representatives.
Within the scope of GDPR, citizens of European Union countries and health tourist clients residing in European Union countries can give their consent for the processing of their personal data in person, provided that they are at least 16 years old or at the age limit stipulated in their country. The consent of clients under this age must be given by their legal representative.
WITHDRAW OF CONSENT
We inform you that if you give consent to DENTIST KUSADASI regarding the processing of your Personal Data, you can withdraw your consent at any time for the purposes stated above in accordance with GDPR 6/1/a and KVKK 5/1. Your consent will be withdrawn if you send your declaration of withdrawal of consent to our contact address below, as indicated below.
RIGHTS OF DATA SUBJECTS IN ACCORDANCE WITH THE BYLAW OF PROTECTION OF GENERAL DATA
As the Data Owner, your Personal Data is also protected in accordance with the GDPR. In cases where GDPR comes under the jurisdiction (European Union citizens 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 whether the personal data concerning him/her is processed or not, by applying to DENTIST KUSADASI, and to learn the details in GDPR article 15 if personal data is processed.
- Right to Rectification (GDPR article 16): The Data Owner has the right to have DENTIST KUSADASI's changed personal data rectified by applying at any time .
- 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 DENTIST KUSADASI. If the issues specified in article 17 of GDPR occur, your personal data will be deleted by DENTIST KUSADASI without delay.
- Right to Restriction of Processing (Article 18 GDPR):
- If the Data Owners object to the up-to-dateness 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 DENTIST KUSADASI.
- 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 DENTIST KUSADASI no longer needs his personal data for the purpose of processing.
- In cases where Data Owners object to the processing in accordance with Article 21/1 of GDPR, they have the right to request the restriction of the use of their data until it is verified whether DENTIST KUSADASI's legitimate reasons for data processing outweigh the Data Owner's legitimate reasons.
- Right to Data Transfer (GDPR article 20): The Data Owner has the right to request the transfer of his Personal Data held by DENTIST KUSADASI to another controller, if technically possible. However, this right may be exercised when data processing is based on consent or when required by the contract .
- Right of Objection (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. DENTIST KUSADASI cannot process Personal Data if it cannot show a strong legitimate reason that is above the interests, rights and freedoms of the Data Owner or such as establishing, exercising or protecting a legal right.
- In cases where his/her Personal Data is processed for direct marketing purposes, the Data Owner always has the right to object to the processing of his/her 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.
DATA OWNERS RIGHTS IN ACCORDANCE WITH KVKK
The rights of natural persons whose Personal Data are processed pursuant to Article 11 of the KVKK are as follows;
- Learning whether personal data is processed or not,
- If personal data has been processed, to request information regarding this,
- Learning the purpose of the processing of personal data and whether they are used in accordance with its purpose,
- Knowing the third parties to whom personal data is transferred at home and abroad,
- Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
- Requesting the deletion or destruction of personal data in the event that the reasons requiring processing are eliminated, although it has been processed in accordance with the provisions of the KVKK and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
- Objecting to the emergence of a result against the person himself by analysing the processed data exclusively through automated systems,
- Requesting the compensation of the damage in case of loss due to unlawful processing of personal data.
If you would like to use any rights or requests from your rights listed above you have to send your written application, in which you clearly and comprehensibly state which of the rights you wish to use in Article 11 of the KVKK or the Articles of GDPR related to the data owner with wet signature and documents to prove your identity, to the address of DENTIST KUSADASI, “Bayraklidede Mah. You can come to Turgut Özal Bulvarı Platin Konakları No:88 Kuşadası/Aydın/Turkey and present it in person, send it via a notary public, or send it to "info dentistkusadasi.com" by signing it with a secure e-signature or by other methods specified in the KVKK. In your applications, name-surname, signature, T.C. Identity Number/Passport Number/temporary T.R. Identity Number, residence or workplace address, e-mail address, telephone and fax number, the matters of the request are required in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller".
DENTIST KUSADASI will conclude the request free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost, the fee in the tariff determined by the Personal Data Protection Board will be charged.
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 DENTIST KUSADASI, 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 DENTIST KUSADASI in accordance with this Information Notice.
You have right not to accept the Information Notice upon reading it.
APEKS AĞIZ DIŞ SAĞLIĞI HIZMETLERI TIC. LTD. ŞTI., is defined as “DATA COLLECTOR” within the scope of KVKK and “CONTROLLER” within the scope of GDPR.
Kind regards.