Esentepe Mah. Büyükdere Cad. No:102 Kat:16 Maya Akar Şişli / İstanbul - Türkiye

+90 212 274 74 66

Clarification Text & KVK Policy

CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA & KVK POLICY

1. PURPOSE:
Health Promotion and Health Policy Association (hereinafter referred to as SHTSPD) shows the highest level of sensitivity regarding the security of personal data and aims to fulfill its responsibilities within the scope of the Personal Data Protection Law No. 6698 (KVKK). This Clarification Text aims to explain the personal data processing activities carried out by SHTSPD and its affiliates, to determine the obligations regarding the protection and processing of personal data in accordance with the LPPD and to inform the data subjects.

In this context, SHTSPD pays special attention to the processing, preservation and destruction of the personal data of the Healthy Turkey Platform, association website members and all other applicants within the SHTSPD within the legal framework.

2. INFORMATION OF THE DATA RESPONSIBLE
SHTSPD, registered in the Associations Registry, is registered at "Esentepe Mah. Büyükdere Cad. No:102 Kat:16 D:63 2-A Maya Akar Şişli/İstanbul" and is the data controller within the scope of the LPPD. SHTSPD assumes data responsibility for all legal entities affiliated to the association under its legal personality.

3. PERSONAL DATA PROCESSING POLICY

a. DATA INTERESTS:

As SHTSPD, our personal data processing policy covers the personal data of the Healthy Turkey Platform, association website members and all other relevant natural persons processed by automatic and/or non-automatic methods.

b. PROCESSED PERSONAL DATA:

The personal data we process as SHTSPD include general data such as identity information (name, surname, T.R. ID number, date of birth, place of birth), contact information (telephone, e-mail address, social media usernames, etc.), professional information (profession and institution of employment), address information (home address, work address).

Special categories of personal data are processed in accordance with the provisions of the KVKK and the relevant legislation, obtaining the explicit consent of the data subjects and in accordance with other legal regulations.


4.

Special categories of personal data of special importance within the scope of the LPPD are; race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or trade union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data. Such data are processed when the necessary legal conditions are met and the explicit consent of the data subjects is obtained.


5. PURPOSE OF DATA PROCESSING:
As SHTSPD, your personal data are processed for the following purposes:

- To carry out the activities of the Association and to provide records,
- To provide communication and to provide opportunities to participate in events,
- To keep member and volunteer records and to communicate,
- To communicate within the scope of organizations and projects,
- To provide information for new projects and collaborations,
- To manage relations and follow sponsorship processes,
- To fulfill legal obligations in accordance with legal regulations.

6. PERSONAL DATA PROCESSING POLICY:

Your personal data is collected by SHTSPD automatically and/or non-automatically by various methods such as e-mail, telephone, website and/or forms kept in paper form.

SHTSPD takes necessary technical and administrative measures for the processing of general and special categories of personal data and carries out processing activities in accordance with the LPPD without harming the fundamental rights and freedoms of data subjects.


7. PERSONS WITH ACCESS TO PERSONAL DATA:

The persons authorized to access personal data within and outside the SHTSPD are as follows:
From within the Association:
- SHTSPD Board Members
- SHTSPD General Coordinatorship
- SHTSPD Employees

From outside the Association:
- Association Consultancy Company
- Employees of the Company Working on the Association Software
- Association Legal Consultancy Office & Association Contracted Lawyer
- Association Accounting Consultancy & Association Contracted CPA

These persons may access and process only the personal data required within the framework of their duties and responsibilities. This access authorization is kept under strict control within the framework of the KVKK and the relevant legislation.

This policy aims to transparently explain the personal data processing processes of the Health Promotion and Health Policy Association and to ensure data security in accordance with the KVKK.

8. TRANSFER OF PERSONAL DATA:
a. DOMESTIC TRANSFER OF PERSONAL DATA

As the Health Promotion and Health Policy Association (SHTSPD), we act in full compliance with the Personal Data Protection Law No. 6698 (KVKK) and the regulations stipulated in the relevant legislation regarding the transfer of personal data. Without prejudice to the reasons for compliance with the law specified in the legislation, personal data and special categories of data are not transferred to third parties without the explicit consent of the data subject.

b. THIRD PARTIES TO WHOM PERSONAL DATA ARE TRANSFERRED BY SHTSPD
Personal data may be transferred to the following categories of persons within the framework of the rules specified in this Policy:
- SHTSPD Board Members
- SHTSPD General Coordinatorship
- SHTSPD Employees
- Legally Authorized Public Institutions and Organizations
- Legally Authorized Private Law Natural / Legal Persons
- Other 3.

c. TRANSFER OF PERSONAL DATA ABROAD
Personal data are generally not transferred abroad without the explicit consent of the data subject. However, in the presence of one of the reasons for compliance with the law specified in this Policy, data may be shared with third parties abroad. In this context:

1. In cases where adequate data protection is provided in the countries where third parties to whom personal data are transferred, or
2. In countries where there is no adequate data protection, there may be cases where data controllers in Turkey and in the relevant country provide adequate protection and the permission of the KVKK Board is obtained.

9. RETENTION OF PERSONAL DATA
As SHTSPD, we retain your personal data for the period required for the purpose for which they are processed and for the minimum period stipulated in the relevant legislation. In determining the periods stipulated for the retention of data, it is first determined whether a period is stipulated for the retention of personal data in the relevant legislation, and if a period is determined, we act in accordance with this period.

If a legal retention period is not determined, personal data is retained for the period required for the purpose for which they are processed. At the end of the specified retention periods, personal data are destroyed in accordance with the periodic destruction periods or the data owner's application and with the specified destruction methods (deletion, destruction, anonymization).

10. PROTECTION OF PERSONAL DATA:
Your personal data are secured by technical and administrative measures taken by SHTSPD. In this context:
- Data processed automatically are stored on the data server and database of SHTSPD.
- Data processed non-automatically are stored in specially prepared compartments at the headquarters of SHTSPD. In particular, data of a special nature is stored in a separate and highly secured area. The majority of physical documents are scanned and securely stored and maintained on SHTSPD's data server.

SHTSPD takes the necessary technical and administrative measures to ensure the security of personal data, conducts or has audits carried out and continuously monitors data security.

11. DISPOSAL POLICY
The Disposal Policy is operated in accordance with the law and relevant legislation and your personal data is destroyed in accordance with the legally determined conditions. Automatically processed and non-physically available data are destroyed by software means, and non-automatic and physically available data are destroyed by secure destruction methods.

12. RIGHTS AND APPLICATION PROCEDURES OF DATA SUBJECTS
a. RIGHTS OF THE DATA SUBJECT:
As data subjects, you have the following rights:
- To learn whether personal data is processed,
- To request information if personal data has been processed,
- To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
- To know the third parties to whom personal data is transferred at home or abroad,
- To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
- Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the Law and other relevant laws, and requesting that the transaction made within this scope be notified to third parties to whom personal data is transferred,
- Objecting to the occurrence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
- Requesting compensation for damages in case of damage due to unlawful processing of personal data.

b. METHODS OF APPLICATION:
In order to exercise your rights mentioned above, your applications can be made in person, by notification through a notary public or by e-mail or mail to the specified contact address. It is important that the information specified during the application is submitted completely and accurately. Your requests will be finalized as soon as possible and within 30 days at the latest, depending on the nature of the request.

13. EFFECTIVENESS AND CHANGE

This disclosure text issued by the Health Promotion and Health Policy Association may be updated to adapt to legal regulations and changing conditions. The updated text will be valid as of the date of publication. The Association reserves the right to make changes in this text and other KVK policies.

Health Promotion and Health Policy Association (SHTSPD) Data Controller
Contact
You can use the contact information below for your requests to exercise your opinions, suggestions and rights.

Address: Esentepe Mah. Büyükdere Cad. No:102 Kat:16 D:63 2-A Maya Akar Şişli/İstanbul
Email: info@saglikliturkiye.org



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