Privacy Policy

We appreciate your interest in our Privacy Policy. This Privacy Policy applies to www.eraysahinsev.com (our “website”).We would like to ask you to read this policy along with our Cookie Policy and if you are a user of our Dental and Health Services, please also refer to our Data Processing Agreement.

General Information

1. What law applies?

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the Turkish Personal Data Protection Law numbered 6698 (“KVKK”) and the EU`s General Data Protection Regulation (“GDPR”).

1. Who is responsible for data processing?

The responsible party within the meaning of the KVKK and the GDPR is Şahinsev Ağız ve Diş Sağlığı Hizm. Ltd.  – Eray Sahinsev Dental Clinic of Kozyatagi District, Şakacı St. No:14/1A Istanbul, 34742, Turkey (“Eray Sahinsev Dental Clinic”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using our Contact Form, WhatsApp us on +90 545 300 7042, call +90 216 658 58 04 or write to us at the above address.

1. What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

1. What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

1. What is processing?

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

1. What are the legal bases of processing?

In accordance with the KVKK and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

• you have given your consent,
• the data is necessary for the fulfilment of a contract / pre-contractual measures,
• the data is necessary for the fulfilment of a legal obligation, or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Data we collect automatically

1. Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

1. Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyses your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the KVKK and the Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

1. Hosting

To provide our website, we use the services of turhost.com (Aerotek Informatics Industry and Trade Inc.), who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

1. Content Management System

We also use the Content Management System (CMS) of WordPress by Automattic Inc to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.

1. Third-party services and content

We use content or service offers of third-party providers to integrate their content and services on our website (“services”). This means that these third-party providers are aware of your IP address, as without your IP address they would not be able to send the content to your browser. Your IP address is therefore necessary for the use of those services and the legal basis for processing your data is our legitimate interest.

Below, we provide an overview of these third-party providers and their services. You can also find a link to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Analytics: Google Analytics by Google LLC,
• Tag Management: Google Tag Manager and Google Site Tag by Google LLC,

• Forms: Contact Form 7 by Takayuki Miyoshi,
• Spam protection: reCAPTCHA by Google LLC, and
• Maps: Google Maps by Google LLC.
• Fonts: Google Fonts by Google LLC,

• Video: YouTube by Google LLC
• Remarketing and Advertisement:
  • Facebook Remarketing by Meta Platforms Inc
  • Google Ads by Google LLC,

If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).

Data we collect directly

1. Contacting us

In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.

For the Chat, we use Zendesk and we process all personal and special category data you voluntarily provide for the purpose of communicating with you. We have no influence on the processing of data by Wix and no possibility to influence it.

In all the above cases, the Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

Please note:

As a rule, we do not require special categories of personal data within the meaning of Art. 9 GDPR to contact you. We ask you not to provide us with such information from the outset. If such information is relevant for contacting you, we process it together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data will be processed by us or on our behalf.

1. Data management and customer support

For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management system (Zendesk). Further and not as an integrated part of our website, we also use a dental data storage system where we keep certain personal data concerning your appointments, x-rays, anamnesis, face photo and the treatments. This data processing is based on our legitimate interest in providing our service.

1. When using our services

We process various data in the course of providing our services, treatment and to initiate and manage the contractual relationship that exists between you and us. As such, we will process your data (if provided: Name, contact details (email address and telephone number), address, and all information required in the context of the performance of the services including health data) exclusively for the purpose of processing and handling the contractual relationship.

When using our Dental and Health Services, you become the data controller and we become the data processor in accordance with the KVKK and the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us. For further information please refer to our Data Processing Agreement.

We process the Personal Data involved in your use of our Dental and Health Services in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

1. Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

1. Service Reviews

We use the rating functions of Google LLC to constantly improve our service, we offer our customers the opportunity to rate us via an independent portal, without us being able to influence this in any way. For this purpose, some date is transmitted to Google. The integration is based on our legitimate interest, and we have no influence or control over the data collected and processed by Google.

1. Comments in our Blog

When you leave comments in our blog or posts, your IP address, your Name, and e-mail address are stored on the basis of our legitimate interests and our contractual obligations to you. This is done for our security in case someone leaves unlawful content in comments and posts. In this case, we can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Within the blog you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. It’s your choice whether to include sensitive information on your comment and to make that sensitive information public. Please do not post or add Personal Data to your comment that you would not want to be available.

1. Marketing

We are entitled to contact you for these purposes via the communication channels you have given your consent to. Our direct marketing typically takes the form of e-mail but may also include other less traditional or emerging channels including social media. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will also include a means by which you may unsubscribe or opt out.

Analytics

We use Google Analytics of Google LLC which means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymized by means of IP anonymization so that an allocation is not possible. Google analytics places cookies. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for the use of Google Analytics is based on your consent.

Principles of processing Personal Data

1. Storage and Retention

At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

1. Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

1. Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

1. Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

1. Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

1. Do Not Sell

We do not sell your Personal Data.

1. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by the Ministry of Health, by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

1. International Transfer

We may transfer your Personal Data as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

Your Rights and Privileges

1. Privacy rights

Under the KVKK and GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

1. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

1. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

1. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

1. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Turkey is: The Turkish Personal Data Protection Authority, Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya , Ankara, Türkiye, www.kvkk.gov.tr

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to speak to us regarding our privacy practices for any reason, please contact us using the details provided above.

Effective Date

10 May 2023