PDP
GENE & GENE
As Gene Gene Biotechnology Software and Trade Limited Company (“Gene & Gene”), we carry out the responsibility of the collection, purpose of use, processing, transfer, storage period and data privacy and protection activities of personal data in accordance with the “Personal Data Protection Law” numbered 6698 within the scope of the relevant law and legislation. For this purpose, we take the highest level of security measures and inform you about your rights. At this point, we attach great importance to the security of your personal data. We preserve all personal data shared by volunteers in a way that will take care of patient privacy and take all necessary technical and administrative measures to ensure the appropriate level of security for your personal data.
This Information on the Protection of Personal Data explains our personal data protection and processing policy and how we collect, use, transfer and protect your personal data during the services provided.
IDENTITY OF THE DATA CONTROLLER
According to the Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the PDP Law in the Information Text), which entered into force on April 7, 2016, your personal data may be processed by Gene Gene Biotechnology Software and Trade Limited Company (hereinafter referred to as Gene & Gene in the Information Text) as the data controller, within the scope explained below.
PURPOSES AND LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA
Articles 5 and 6 of the PDP Law regulate the conditions for processing personal data and special personal data. Special personal data are specified in the Law in a limited manner and include data regarding the race, ethnic origin, political opinion, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures of individuals, as well as biometric and genetic data. While Article 5 of the Law determines the processing conditions of non-special personal data, the processing conditions of special data are regulated in Article 6.
According to Article 5 of the Personal Data Protection Law, the processing conditions of non-special personal data are as follows;
▪ The explicit consent of the data owner.
▪ Data processing is clearly prescribed by law.
▪ The processing of relevant data is mandatory for the protection of the life or physical integrity of the person who is unable to express his/her consent due to a de facto impossibility or whose consent is not legally valid, or of another person.
▪ The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract.
▪ Data processing is mandatory for the data controller to fulfill its legal obligation.
▪ Personal data is made public by the relevant person.
▪ Data processing is mandatory for the establishment, exercise or protection of a right.
▪ Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.
Conditions for processing special personal data according to Article 6 of the Personal Data Protection Law;
▪ The explicit consent of the data owner,
▪ Processing of special personal data other than health and sexual life (individuals' race, ethnic origin, political opinion, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, criminal conviction and security measures, and biometric and genetic data is foreseen by law.
Within the framework of these conditions, your personal data;
▪ Fulfilling our legal obligations in the relevant legal regulations,
▪ Contacting you in research (telephone, SMS, e-mail),
▪ Protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing,
▪ Providing you with information about your appointment if you make an appointment,
▪ Planning and managing the internal functioning of Gene & Gene,
▪ Performing analysis to improve our services,
▪ Verifying your identity,
▪ Your relationship with contracted institutions verification,
▪ Responding to the requests of the Ministry of Health and other public institutions and organizations in accordance with the applicable legislation,
▪ Responding to your questions or complaints regarding our services,
▪ Analyzing your use of health research services in order to improve the services we provide,
▪ Complying with Gene & Gene's internal policies and principles,
▪ Measuring and increasing patient satisfaction following your receipt of health services,
▪ Contacting you for information regarding our services,
▪ Procuring medicines or medical devices,
Your personal data is archived, processed and used in electronic or physical environments within the purposes specified by taking the necessary security, confidentiality and legal measures.
However, your personal data will not be used for any commercial purpose other than the activities listed above and as required by the relevant legislation.
PERSONAL DATA COLLECTED BY GENE & GENE
We collect various information from volunteers within the scope of the health/research services we provide. The information in question is collected in accordance with the data processing principles and conditions set forth in the Personal Data Protection Law No. 6698 (“KVKK”) under all circumstances. The information we collect from you for the purposes of processing personal data may include the following:
- Your name, surname
- Your month and year of birth,
- Your gender,
- Your telephone number,
- Your e-mail address,
- Your health data including but not limited to your examination, x-ray and tomography data, prescription information,
- Your voice recording when you contact us or when we call you,
- Your health data and identity information you share when you use the online services on our website,
- Other data you share when you reach us via e-mail, call center or other channels.
PROTECTION OF YOUR PERSONAL DATA
Personal data shared with Gene & Gene is under the supervision and control of Gene & Gene. Gene & Gene has assumed responsibility as the data controller to establish the necessary organization and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the relevant legislation in force. We would like to inform you that we periodically conduct penetration tests in accordance with international and national technical standards regarding data privacy, being aware of our obligations in this regard, and that we always update our data processing policies within this scope.
PERSONS AND ORGANIZATIONS TO WHICH YOUR PERSONAL DATA MAY BE TRANSFERRED AND THE PURPOSES OF TRANSFER
To fulfill our legal obligations set forth in the Health Services Fundamental Law No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Private Hospitals Regulation, the Regulation on the Processing and Ensuring Privacy of Personal Health Data, and other relevant regulations;
Parties whose transfer details you have accepted in the informed consent form for the purpose of participating in the research,
To ensure that all necessary technical and administrative measures are taken to ensure the appropriate level of security in accordance with the KVKK and relevant health legislation, and to ensure that the relevant units carry out the necessary work in order to enable the relevant persons to benefit from the products and services offered by our Institution,
To fulfill the administrative and economic activities of our Institution,
To ensure and supervise physical security in the buildings belonging to our Institution, to carry out legal, financial and administrative compliance processes, to fulfill financial, legal and administrative affairs, in line with the purposes of this disclosure text; to institutions or organizations permitted by the relevant legislation; to all Ministries, judicial bodies; to private insurance companies; to our direct/indirect domestic/foreign shareholders, affiliates and/or subsidiaries; to auditors; to consultants; to business partners; It is possible to transfer to domestic/foreign organizations and other third parties from whom we receive contractual services and cooperate to carry out our activities, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law.
METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA
Your personal data is collected in order to provide our services in line with the purposes stated above and to ensure that our institution fulfills its responsibilities arising from the contract and the law completely and correctly. Your collected personal data can be processed and transferred for the purposes specified in this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law.
Within the scope of the legal reasons stated above, your personal data is collected through all kinds of verbal (all kinds of declarations, etc.), written (tests, job application forms, communication forms, patient consent forms, etc.) or electronic media, through the call center, your declared identity document, website, social media areas, our institution's website, mobile applications and existing camera recording systems.
YOUR RIGHTS REGARDING YOUR PERSONAL DATA
According to Article 11 of the Personal Data Protection Law, you can apply to the data controller and ask for;
▪ To learn whether your personal data has been processed,
▪ To request information about your personal data if it has been processed,
▪ 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,
▪ Request correction of your personal data if it is processed incompletely or incorrectly and request notification of the transaction made to third parties to whom your personal data is transferred,
▪ Request deletion or destruction of personal data if the reasons requiring processing are eliminated despite the fact that it has been processed in accordance with the PDP Law and other relevant provisions of law and request notification of the transaction made to third parties to whom your personal data is transferred,
▪ Object to any adverse result that may arise from the analysis of the processed data exclusively through automated systems,
▪ Request compensation for the damages if you suffer damages due to the unlawful processing of your personal data.
METHODS YOU SHOULD FOLLOW TO EXERCISE YOUR RIGHTS
According to Article 13, paragraph 1 of the PDP Law, you can submit your applications regarding your rights specified above by filling out the Related Person Application Form to
▪ Fevzipaşa Mah. You can personally deliver it to Mercimek Cad. E-Blok 13-14 Nolu No/49/14 Didim/AYDIN address with documents proving your identity,
▪ You can send it through a notary or other methods specified in the Personal Data Protection Law,
▪ You can send the relevant form to hello@geneandgene.com e-mail address with a secure electronic signature.
As the relevant person within the scope of legal obligations regarding the application procedures and principles to the data controller; you must include your name, surname, signature if your application is in writing, your Turkish Republic ID number if you are a citizen of the Republic of Turkey, your nationality if you are a foreigner, your passport (or ID number if you have one), your place of residence or business address for notification, your e-mail address and fax number for us to use as the basis for notification, and finally the subject of the request. In addition to these, you must attach identity-providing documents and information and documents regarding the subject of your request to your application. In order for us to operate the process in the most effective way for you, you must clearly and understandably state which right you want to exercise in your request and the details of the transaction you request. We would like to emphasize that the subject of the request must be related to the relevant person. If the application is being made on behalf of someone else, the person making the request must rely on a specifically documented authority (power of attorney) for the requested transaction. Unauthorized applications will not be evaluated. Depending on the nature of your request, your applications will be finalized free of charge within thirty days at the latest; however, in the event of an additional cost, our Institution reserves the right to request a fee from you according to the tariff to be determined by the Personal Data Protection Board.
EXPLICIT CONSENT DECLARATION REGARDING THE PROCESSING, USE AND SHARING OF PERSONAL DATA
Dear Data Owner;
According to the Personal Data Protection Law No. 6698 (“LPPD”), any information that enables a natural person to be identified or made identifiable is within the scope of personal data.
In this context, your personal data will be processed, stored, preserved, updated when necessary as the Data Controller in the Gene & Gene Information Text, disclosed/transferred to third parties within the circumstances specified in the Information Text and within the limits of legislation and law, and processed in the ways specified in the PDP Law.
You have the right to apply to our institution in accordance with Article 11 of the PDP Law and have your personal data;
1. Learn whether it has been processed,
2. Request information if it has been processed,
3. Learn the purpose of processing and whether it is used in accordance with its purpose,
4. Know the third parties to whom it has been transferred domestically or abroad,
5. Request correction if your data is processed incompletely or incorrectly,
6. Request deletion/destruction within the framework of Article 7 of the PDP Law,
7. Request compensation for damages if you suffer damages due to processing in violation of the law.
Within the scope of the Law on the Protection of Personal Data No. 6698 (“Personal Data Law”);
- In accordance with the “Regulation on the Processing and Ensuring Privacy of Personal Health Data”; as the data controller, we, as Gene & Gene, will record and store in our archives and process your personal information required for patient benefit, public health and scientific studies,
- Within the scope of the relevant legislation, as a contracted research organization, we are obliged to record your initials, phone number, medical history and all other necessary information to identify the information of you volunteers; to organize all records and documents to be included in the source file that will form the basis of the process in electronic or paper format,
- In case of a request by the authorized authorities, by persons assigned by the authorized authorities or within the scope of the established e-pulse and similar systems, or within the scope of our notification and/or reporting obligations imposed on us, we inform you that your personal data will be shared with the relevant authorities and persons.