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KVKK

Personal Data Processing and Protection Policy

(KVKK – Law No. 6698)

Purpose of the Policy

The purpose of this Personal Data Processing and Protection Policy (“Policy”) is to determine the principles adopted by Fertilis regarding the processing, protection, storage, and transfer of personal data in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and other relevant legislation.

Within this scope, this Policy aims to:

  • Ensure that all personal data processed by Fertilis is handled in compliance with KVKK and related regulations,

  • Define the procedures and principles regarding the protection of personal data belonging to our patients, visitors, employees, business partners, suppliers, and other related individuals,

  • Inform data subjects about how their personal data is processed, stored, and protected,

  • Establish internal guidelines and operational standards for Fertilis employees regarding the lawful processing of personal data.

Fertilis adopts the protection of personal data as a fundamental corporate responsibility and implements the necessary administrative and technical measures to ensure that personal data is processed in compliance with applicable laws and regulations.

Implementation and Amendment of the Policy

This Policy is implemented by Fertilis and applies to all departments, employees, and stakeholders involved in the processing of personal data.

Fertilis reserves the right to amend, update, or revise this Policy when necessary in order to ensure compliance with:

  • The Law on the Protection of Personal Data No. 6698 (KVKK)

  • Relevant regulations issued by the Personal Data Protection Authority

  • Developments in legal, technological, or operational requirements.

Any updates or amendments to this Policy will be published through the relevant communication channels of Fertilis.

Scope of the Policy

This Policy covers all personal data processed by Fertilis, whether processed fully or partially by automated means or by non-automated means provided that they form part of a data recording system.

The scope includes personal data belonging to:

  • Patients and prospective patients

  • Website visitors and online service users

  • Employees and job applicants

  • Business partners and suppliers

  • Consultants and service providers

  • Visitors to Fertilis facilities

  • Other individuals whose personal data may be processed within the scope of our services

Fertilis ensures that all personal data processing activities comply with the fundamental principles set forth under Article 4 of KVKK, and necessary administrative and technical safeguards are implemented to ensure data security.

Additionally, Fertilis conducts internal training programs and awareness activities to ensure that employees understand their responsibilities regarding personal data protection.

Fundamental Principles for the Processing of Personal Data

Fertilis processes personal data in accordance with the following fundamental principles defined under Article 4 of KVKK:

1. Processing in Compliance with the Law and Principles of Good Faith

Personal data is processed in accordance with the Constitution of the Republic of Türkiye, KVKK, and other relevant legislation. Fertilis ensures that personal data is obtained through lawful means and processed in line with the principles of transparency, fairness, and good faith.

2. Ensuring Accuracy and Keeping Data Up to Date

Fertilis takes reasonable steps to ensure that personal data is accurate, complete, and kept up to date where necessary. In this regard, mechanisms are implemented to allow data subjects to update or correct their personal information when needed.

3. Processing for Specific, Explicit, and Legitimate Purposes

Personal data is processed only for specific, explicit, and legitimate purposes. Fertilis clearly defines the purposes for which personal data is collected and ensures that data is not processed beyond those purposes.

4. Processing in a Relevant, Limited, and Proportionate Manner

Fertilis ensures that personal data processing activities are relevant, limited, and proportionate to the purposes for which the data is processed. Only the personal data necessary to achieve the intended purpose is collected and processed.

5. Retention for the Period Required by Law or the Processing Purpose

Personal data is stored only for the duration required by applicable laws or for the period necessary to fulfill the purposes of processing. Once the retention period expires, personal data is deleted, destroyed, or anonymized in accordance with the Personal Data Retention and Destruction Policy.

Administrative and Technical Measures

Fertilis takes all necessary administrative and technical measures to ensure the security of personal data and prevent unlawful access, disclosure, loss, or misuse.

These measures include, but are not limited to:

  • Access control mechanisms

  • Data encryption and secure data storage systems

  • Internal authorization procedures

  • Employee training and awareness programs

  • Data processing agreements with third parties

  • Regular internal audits and compliance checks

Through these measures, Fertilis aims to ensure that personal data remains protected against unauthorized access, accidental loss, destruction, or alteration.

Rights of Data Subjects

In accordance with Article 11 of KVKK, data subjects have the following rights regarding their personal data:

  • To learn whether their personal data is being processed,

  • To request information regarding the processing of their personal data,

  • To learn the purpose of processing and whether it is used in accordance with that purpose,

  • To know the third parties to whom personal data is transferred domestically or abroad,

  • To request correction of incomplete or inaccurate personal data,

  • To request deletion or destruction of personal data where the reasons for processing no longer exist,

  • To request notification of correction or deletion to third parties to whom data has been transferred,

  • To object to outcomes resulting from automated data processing that adversely affect them,

  • To claim compensation in case of damages caused by unlawful processing of personal data.

Requests regarding these rights may be submitted to Fertilis through the communication channels specified on our website.

Commitment to Personal Data Protection

Fertilis acknowledges the protection of personal data as a fundamental right and undertakes to process personal data in accordance with KVKK, the Constitution of the Republic of Türkiye, and internationally accepted data protection principles.

Our institution continuously improves its data protection practices to ensure that personal data belonging to patients, employees, and business partners is processed in a secure, transparent, and lawful manner.