SMIRNI HEALTH SERVICES TOURISM CONSULTANCY TRADE LIMITED COMPANY
INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA (KVKK)
DATA CONTROLLER IDENTITY
Address: Kartaltepe Neighborhood, Saydam Street No:13/A, Küçükçekmece / Istanbul
(Phone: +90 544 958 17 19 – +90 538 971 49 33)
Operating at the above address:
SMIRNI HEALTH SERVICES TOURISM CONSULTANCY TRADE LIMITED COMPANY
(operating under the brand name “Quality Life Health Travel”)
1. Data Controller
Within the scope of the Personal Data Protection Law No. 6698 (“KVKK”), the data controller is:
SMIRNI HEALTH SERVICES TOURISM CONSULTANCY TRADE LIMITED COMPANY
Website: https://qualitylifehealth.com
E-mail: info@qualitylifehealth.com
Address: Kartaltepe Neighborhood, Saydam Street No:13/A, Küçükçekmece / Istanbul
2. Categories of Personal Data Processed
The following personal data shared by you and obtained within the scope of the service process may be processed:
Identity Data:
Full name, passport information, date of birth, nationality.
Contact Data:
Phone number, e-mail address, WhatsApp contact information, address information.
Health Data (Special Category Personal Data):
Your health-related sensitive personal data are processed only for the purposes of organizing health tourism services, including appointment planning, coordination of treatment processes, transfer of patient files to authorized healthcare institutions, planning travel and accommodation arrangements in line with treatment processes, and fulfilling notification obligations arising from legislation, through authorized healthcare institutions and physicians and under their responsibility.
Financial Data:
Invoice information, payment records.
Logistics Data:
Flight, transfer, and accommodation reservation details.
Digital Data:
IP address, cookie records, website usage data, form and application records.
3. Purposes of Processing Personal Data
Your personal data are processed for the following purposes:
Planning activities carried out directly or indirectly by Quality Life Health Travel
Conducting health tourism intermediary services
Organizing clinic, hospital, and doctor appointments
Ensuring coordination between patient, clinic, and intermediary institution
Creating patient registrations on the HealthTürkiye portal within the scope of the Health Tourism Regulation, making treatment-related notifications, entering treatment result reports into the system, and carrying out notifications and reporting requested by USHAŞ in accordance with applicable legislation and USHAŞ regulations
Planning transfer, accommodation, and travel arrangements
Carrying out accounting and finance processes
Managing patient communication processes via WhatsApp Business, telephone, and e-mail channels
Managing patient follow-up processes through the CRM system (Bitrix24)
Improving service quality and operational processes
Resolving complaints regarding the services provided and processing requests for data access or correction
Fulfilling legal obligations
Ensuring the legal security of Quality Life Health Travel
Carrying out advertising, promotion, marketing, and social media activities where explicit consent has been obtained
4. Legal Basis
Your personal data are processed within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) based on the following legal grounds:
KVKK Article 5/2-c (Establishment and Performance of a Contract):
Your personal data may be processed for the purpose of establishing and performing the contract to which you are a party and fulfilling obligations arising from such contract.
KVKK Article 5/2-ç (Fulfillment of Legal Obligations):
Your personal data may be processed for the purpose of fulfilling legal obligations arising from applicable legislation (such as accounting, tax, labor law, and notification obligations to public authorities).
KVKK Article 5/2-f (Legitimate Interest):
Provided that your fundamental rights and freedoms are not harmed, your personal data may be processed for the protection of the legitimate interests of the data controller and for the continuation of its activities.
Processing of Health Data under KVKK Article 6/3:
Your health-related sensitive personal data may be processed for the purposes of organizing health tourism services for domestic and international patients, directing patients to healthcare institutions, appointment planning, coordination of treatment processes, transferring patient files to authorized healthcare institutions, planning travel and accommodation in line with treatment processes, and fulfilling obligations arising from legislation, through authorized healthcare institutions and physicians and under their responsibility.
In Cases Where Explicit Consent Is Obtained – KVKK Articles 5/1 and 6/2:
In cases where other legal grounds for processing stipulated by law are not available, your personal data and sensitive personal data are processed based on your explicit consent.
5. Transfer of Personal Data
Your collected personal data may be shared, within the scope of Articles 8 and 9 of the Personal Data Protection Law No. 6698, and limited to the purposes of conducting health tourism services, appointment organization, planning treatment processes, patient transfer and accommodation arrangements, invoicing, and fulfilling legal obligations.
Within this scope, your personal data may be shared with:
Ministry of Health, USHAŞ, and affiliated platforms (including Health Türkiye)
Contracted clinics, physicians, and hospitals
Transfer and accommodation companies (limited to logistics data only)
Banks, accounting, and e-invoice service providers
CRM systems
Internal company data sharing and authorization units
Information technology infrastructure service providers (server, software, cloud systems)
Persons and institutions providing legal and financial consultancy services
Authorized public institutions and organizations
Insurance companies (if requested)
All transfers are carried out in compliance with KVKK provisions.
6. Method of Collecting Personal Data
Your personal data are collected verbally, in writing, or electronically, through automatic or non-automatic methods, via Quality Life Health Travel’s website, HealthTürkiye platform, social media accounts, call center, e-mail, mobile applications, online application forms, contracts, and similar communication channels.
Your personal data may be processed, updated, and stored for the purposes of enabling you to benefit from health tourism services, carrying out treatment organization processes, ensuring domestic and international patient coordination, creating appointments, planning transfer and accommodation arrangements, fulfilling legal notification obligations, and entering data into HealthTürkiye and USHAŞ systems.
7. International Transfer of Personal Data
Within the scope of organizing health tourism services, personal data processed may be transferred abroad due to the information systems used in service processes. In this context, data may be transferred to servers located abroad through information systems used for customer relationship management and communication activities. Such data transfers are carried out in accordance with Article 9 of the Personal Data Protection Law No. 6698 and, where necessary, based on explicit consent.
SMİRNİ SAĞLIK HİZMETLERİ operates as an intermediary service provider within the scope of health tourism and is not directly responsible for medical diagnosis, treatment, or procedures. In this regard, all responsibility arising from the relevant medical procedures belongs to the authorized healthcare institutions and the relevant physicians providing the service.
Personal data is stored in accordance with the retention periods stipulated by the relevant legislation and in line with the purposes of processing. In this context: health data is retained for the periods prescribed under the applicable legislation; financial and accounting records are retained for 10 years; customer relationship management (CRM) data is retained for the duration of the service and thereafter for the period required by legislation; marketing data is retained until explicit consent is withdrawn; and website usage and log records are retained for 2 years. At the end of the retention period, personal data is deleted, destroyed, or anonymized in accordance with the relevant legislation.
8. Data Retention Periods
Health data: For the periods stipulated by applicable legislation
Financial and accounting records: 10 years
CRM records: Service duration + statutory retention period
Marketing data: Until explicit consent is withdrawn
Website and log records: 2 years
9. Rights of the Data Subject
Pursuant to Article 11 of the KVKK, you have the right to:
Learn whether your personal data are being processed
Request information regarding such processing
Request correction of your personal data
Request deletion or destruction of your personal data
Learn the third parties to whom your personal data have been transferred
Object to results arising against you through automated systems
Request compensation in case of damage
CONTACT US FOR YOUR REQUESTS
If you wish to contact us, provide feedback, or direct your questions within the scope of Law No. 6698, you may submit your request in person to:
KARTALTEPE MAH. SAYDAM SOK. NO:13/A KÜÇÜKÇEKMECE / ISTANBUL
together with documents verifying your identity and a written petition containing your request.
You may also apply through an authorized representative by submitting a notarized power of attorney proving authorization under Article 11, either in person or through a notary public.
In addition, pursuant to Article 5 of the Communiqué on the Principles and Procedures for Application to the Data Controller, you may send your request to:
smirnisaglikhizmetleri@hs01.kep.tr
by using a secure electronic signature, mobile signature, or the e-mail address previously notified to us and registered in our systems.
Written applications submitted in this scope will be accepted following identity verification and will be responded to in writing or electronically within the legal period.
Applications will be concluded free of charge by the data controller; however, if the process requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.
