INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA THROUGH COOKIES
https://qualitylifehealth.com/
This Information Notice has been prepared pursuant to Article 10 of the Law No. 6698 on the Protection of Personal Data and the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform, by Smirni Sağlık Hizmetleri Turizm Danışmanlık Ticaret Limited Şirketi (“Company”) in its capacity as data controller. Article 10 of Law No. 6698 imposes an obligation to inform on data controllers; the Communiqué regulates the scope and procedures of this obligation. In addition, the Cookie Practices Guide published by the Personal Data Protection Authority serves as a guiding document with respect to personal data processing activities carried out through cookies.
We use cookies in certain areas of our website https://qualitylifehealth.com/ (“Site” or “Website”). This Information Notice on the Processing of Personal Data Through Cookies applies to the website managed by our Company and is implemented within the framework of the principles explained below.
The purpose of this Information Notice is to inform you about the purposes for which personal data obtained automatically through the placement of cookies on your device via our website are processed, the types of cookies used, the legal bases on which these cookies rely, the parties with whom such cookies may be shared, and how you can manage your cookie preferences. As also stated in the Cookie Practices Guide, for cookies other than strictly necessary cookies, explicit consent must be obtained and the withdrawal of such explicit consent must be made as easy as giving consent.
Except for strictly necessary cookies used on our website and cookies that are technically required for the provision of services, functional, performance-analytical, and advertising/marketing cookies are operated only upon obtaining the explicit consent of the relevant individuals. Users may view the categories of cookies used on our website via the cookie management panel, set their preferences as “on” or “off” for cookies other than strictly necessary cookies, and may change their preferences at any time through the same panel thereafter. This approach is in line with the preference management principles adopted in the Authority’s cookie guide.
- GENERAL INFORMATION ON COOKIES
- What Are Cookies?
Cookies are small text files created on your device by a website and containing data in name-value format. Cookies enable the website you visit to store information on your device and use this information during your subsequent visits. Cookies created by a website are stored by the internet browser you use to access the site, and access to the information contained in cookies is, in principle, limited to the relevant domain name.
Although cookies do not necessarily contain information such as name, surname, or address, they may become personal data when combined with online identifiers, device information, preference records, and usage habits. The Authority’s Guide also clearly states that online identifiers should, under certain conditions, be considered personal data.
Cookies are an important part of today’s internet technologies; their basic functions include remembering the preferences of online visitors, recognizing the device during connection, improving user experience, ensuring the secure and efficient operation of the website, and, in some cases, carrying out analytical and advertising activities. However, in the use of cookies, compliance with the principles of lawfulness, specific and legitimate purpose, proportionality, and data minimization under the Law is mandatory.
- Who Sends Cookies and How?
Cookies are sent through the communication established between your internet browser on your device and the website servers during your visit to our website. These cookies may be placed directly by our Company or may also be placed through third parties providing infrastructure, analytics, measurement, advertising, or similar technology services used by our Company.
- What Are the Types of Cookies?
- According to Ownership
- First-Party Cookies: Cookies placed on the device directly by the visited website, namely by our Company.
- Third-Party Cookies: Cookies placed on the device by third parties providing analytics, advertising, measurement, or similar services in cooperation with our Company.
- According to Duration
- Session Cookies: Cookies that remain active until the user closes the browser or the session ends.
- Persistent Cookies: Cookies that remain stored on the device for a specified period and remain until the expiry of that period or until deleted by the user.
- According to Purpose of Use
- Strictly Necessary Cookies: Cookies required for the operation of the website, ensuring security, and performing essential functions.
- Functional Cookies: Cookies that help remember user preferences and personalize the website.
- Performance and Analytical Cookies: Cookies used to provide statistical data regarding website usage, evaluate usage intensity, visitor behavior, and performance measurements.
- Advertising and Marketing Cookies: Cookies used for displaying content and advertisements based on your interests, measuring the effectiveness of advertising campaigns, and carrying out targeted promotional activities. The Cookie Practices Guide of the Authority also classifies cookies in this manner according to their purpose of use.
- PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA THROUGH OUR WEBSITE
For foreign users who access our services largely from abroad, your personal data obtained through cookies may consist of online data such as IP address, browser information, device information, visit time, session information, cookie consent and rejection preferences, page view activities, language and interface preferences, traffic data, and usage habits. These data are processed in accordance with the purposes and legal bases explained below.
- Strictly Necessary Cookies
Purpose:
• To ensure the secure operation of the website,
• To manage user sessions and cookie preferences,
• To prevent system errors and fulfill technical requirements that directly affect user experience,
• To operate the basic functions of the website,
• To carry out network and information security processes.
Legal Basis:
• Article 5/2-c of the PDPL: “Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract,”
• Article 5/2-ç of the PDPL: “Processing is necessary for the data controller to fulfill its legal obligation,”
• Article 5/2-f of the PDPL: “Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”
Since strictly necessary cookies constitute a technical requirement for the operation and security of the website, no separate explicit consent is required for these cookies. This approach is in line with the framework set out in the Cookie Practices Guide.
- Functional Cookies
Purpose:
• To make our website more functional,
• To remember user preferences and choices regarding website usage,
• To personalize the site experience.
Legal Basis:
• Article 5/1 of the PDPL: “Explicit consent of the data subject.”
Functional cookies are activated only if explicit consent is given, and are not activated if consent is not provided. The Law clearly regulates that explicit consent must be specific, informed, and freely given.
- Performance and Analytical Cookies
Purpose:
• To measure website performance,
• To analyze visitor behavior,
• To evaluate how users use the website,
• To detect errors and carry out improvement processes,
• To generate statistical reports based on page views, visit duration, and session data,
• To improve website content and user experience.
Legal Basis:
• Article 5/1 of the PDPL: “Explicit consent of the data subject.”
Since performance and analytical cookies are not considered strictly necessary cookies, they are used only upon obtaining explicit consent. The Authority’s Guide also states that cookies used for statistical and analytical purposes are subject to explicit consent, except in certain conditions.
- Advertising and Marketing Cookies
Purpose:
• To provide content and advertisements tailored to the user’s interests,
• To measure the effectiveness of advertising campaigns,
• To carry out targeted promotional activities based on user preferences,
• To perform data matching with third-party advertising platforms.
Legal Basis:
• Article 5/1 of the PDPL: “Explicit consent of the data subject.”
Advertising and marketing cookies are also activated only if explicit consent is provided, and such consent may be withdrawn by the relevant individual at any time.
In addition, your website browsing data, IP address information, website login and logout information, traffic data, and security records may be processed for the purposes of fulfilling obligations arising from Law No. 5651 and related secondary legislation, ensuring network and information security, conducting access activities, ensuring compliance with legislation, following legal affairs, ensuring business continuity, securing the operations of the data controller, informing authorized persons, institutions, and organizations, and managing risk processes. These processing activities are based on the legal grounds of fulfilling the legal obligations of the data controller and protecting its legitimate interests. Article 5 of the PDPL regulates data processing conditions in its current version accordingly.
III. SHARING OF YOUR PERSONAL DATA
Your personal data obtained through cookies may be shared, strictly limited to the processing purposes stated above, with domestic or foreign technology providers from whom we receive services, analytics service providers, CRM and customer relationship management system providers (Bitrix24), advertising and marketing infrastructure providers, hosting and support service providers, and, if your explicit consent is obtained, with our business partners. In addition, your personal data may also be transferred for the purpose of fulfilling legally compliant requests from authorized public institutions and organizations and within the scope of fulfilling our legal obligations.
In data transfer processes, compliance is ensured with the conditions set forth in Articles 8 and 9 of the PDPL; for cross-border data transfers, the current Article 9 of the Law and the relevant transfer regime are taken into account. In cross-border transfers, mechanisms such as explicit consent, adequacy decisions, or appropriate safeguards are used based on the applicable legal framework. The current version of Law No. 6698 clearly regulates adequacy decisions and appropriate safeguard mechanisms for cross-border data transfers.
- STORAGE AND DELETION OF YOUR PERSONAL DATA
Our Company retains your personal data only for the period necessary for the purposes of data processing and within the retention periods stipulated in the relevant legislation. Once the retention period expires or the purpose of processing ceases to exist, personal data is deleted, destroyed, or anonymized in accordance with Article 7 of the PDPL and the provisions of the Regulation on the Deletion, Destruction or Anonymization of Personal Data. Article 7 of the Law and the related secondary legislation explicitly impose this obligation on data controllers regarding personal data whose processing conditions no longer exist.
Personal data obtained through cookies may also be deactivated if you change your preferences via your browser settings or the cookie management panel. Data stored on systems under the control of our Company is deleted, destroyed, or rendered unusable through technical means. However, for cookies placed by third-party providers, the retention and deletion policies of such providers may also apply separately.
- YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA
Pursuant to Article 11 of the PDPL, you may exercise the following rights by applying to our Company:
- a) To learn whether your personal data is processed,
b) To request information if your personal data has been processed,
c) To learn the purpose of processing your personal data and whether it is used in accordance with its purpose,
ç) To learn the third parties to whom your personal data is transferred domestically or abroad,
d) To request correction of your personal data if it is incomplete or incorrectly processed,
e) To request deletion, destruction, or anonymization of your personal data within the scope of Article 7 of the PDPL,
f) To request notification of the operations carried out pursuant to (d) and (e) to third parties to whom your personal data has been transferred,
g) To request data portability (for data subjects residing in the EU/EEA, Article 20 of the GDPR), to object to the emergence of a result against you through the analysis of processed data exclusively via automated systems,
ğ) To request compensation for damages in case you suffer harm due to unlawful processing of your personal data.
These rights are clearly regulated under Article 11 of Law No. 6698. The procedures for applications are set out in the Communiqué on the Procedures and Principles of Application to the Data Controller. Pursuant to the Communiqué, the data controller is obliged to conclude duly submitted applications within thirty days at the latest; if the process requires additional costs, a fee may be charged according to the tariff determined by the Board.
You may submit your requests to our Company in accordance with the relevant legislation through the following channels:
Title: Smirni Sağlık Hizmetleri Turizm Danışmanlık Ticaret Limited Şirketi
Address: Kartaltepe Mah. Saydam Sk. No:13/A Küçükçekmece / Istanbul
E-Mail: consultancy@qualitylifehealthtravel.info
Phone: +90 538 971 49 33
Website: qualitylifehealth.com
In order for a person other than the data subject to make a request, a notarized special power of attorney issued in the name of the data subject is required. Our Company may request additional information to verify whether the applicant is the data subject and may ask questions to the relevant individual in order to clarify the matters stated in the application.
Applications duly submitted to our Company shall be finalized within thirty days at the latest. If the request requires additional costs, the fee determined in the tariff set by the Personal Data Protection Board may be applied. The procedures for application to the data controller and pricing principles are regulated in the Communiqué.
The data subject may, pursuant to Article 14 of the PDPL, lodge a complaint with the Board within thirty days from the date of learning of the response of the data controller, and in any case within sixty days from the date of application, in cases where the application is rejected, the response is found insufficient, or no response is given within the time limit. This right is also regulated in the current version of the Law.
- COOKIE INFORMATION LIST
The cookie list provided below is for informational purposes regarding the categories of cookies that may be used on our website. The Company keeps the cookies actually used up to date in accordance with the cookie management panel, cookie inventory, and technical detection studies. The names, providers, storage periods, and purposes of the cookies used may be updated depending on technical infrastructure changes.
- Strictly Necessary Cookies
These cookies are required for the proper functioning of the website and enable users’ privacy preferences, session management, security, and the provision of basic services.
| Identifier | Provider | Description | Type | Retention Period |
| wp-wpml_current_language | qualitylifehealth.com | Stores the user’s language preference for the site. | First-Party | Session |
| cookie-consent | qualitylifehealth.com | Stores cookie preference records and consent status. | First-Party | Duration of preference |
| dont-offer-english | qualitylifehealth.com | Helps manage language and interface preferences. | First-Party | Session |
- Functional Cookies
These cookies are used to make our website more functional and personalized, and to remember user preferences and previously made selections.
(Currently, no independent functional cookies have been technically detected. This section will be updated if necessary.)
- Performance and Analytical Cookies
These cookies are used to monitor website performance, improve services, analyze visits, and understand user behavior.
| Identifier | Provider | Description | Type | Retention Period |
| _fbp | Meta (Facebook) | Enables measurement of advertising and analytics performance by distinguishing visitors. | Third-Party | Approximately 3 months |
- Advertising and Marketing Cookies
These cookies are used to show users content and advertisements based on their interests, measure campaign performance, and conduct targeted advertising activities.
| Identifier | Provider | Description | Type | Retention Period |
| fr | Meta (Facebook) | Used to deliver personalized ads and measure ad performance. | Third-Party | Approximately 3 months |
| datr | Meta (Facebook) | Identifies the user for security and fraud prevention purposes. | Third-Party | Approximately 1 year |
| sb | Meta (Facebook) | Used for browser identification and security purposes. | Third-Party | Approximately 1 year |
| ps_l | Meta (Facebook) | Supports proper functioning of Facebook services. | Third-Party | Short-term |
| ps_n | Meta (Facebook) | May be used in advertising and analytics processes. | Third-Party | Approximately 1 year |
Cookie Management via Browser
You can configure your browser to block cookies for all sites or specific sites, to notify you when a cookie is created, to block third-party cookies, or to treat all cookies as session cookies. You can also delete cookies through your browser or view the list of stored cookies. However, if you block all cookies via your browser settings, you may not be able to fully benefit from some features of our website.
In addition, you may manage certain analytical or advertising cookies through preference and opt-out mechanisms provided by relevant third-party providers. However, the preference and deletion processes related to third-party cookies are subject to the data policies and systems of the respective third parties.
