Update Date: September 1, 2023

This Privacy Policy and Visitor Clarification Text (Policy) has been prepared in order to enlighten and inform the Visitors about the terms and conditions regarding the use of the data obtained and/or to be obtained by Dr. Umur Akıner (Akıner) as the data controller and the ways of processing the data by accessing the website umurakiner.com (Site) or due to the use of the Site in any way; or due to the visit of the data subjects to the physical locations of Dr. Umur Akıner.

In addition, this Policy also covers the principles and rules adopted by AKINER in data usage scenarios where AKINER accesses personal data in any way as a data processor.

1. General Explanations

Personal data refers to any information relating to an identified or identifiable natural person. For this reason, the regulations on personal data in this text shall apply if the relevant information belongs to a natural person. If the relevant information belongs to legal entities, the regulations other than the regulations on personal data in this text shall apply.

AKINER attaches importance to the confidentiality of data and takes care to be transparent about the storage of information. This Policy is a privacy policy that includes what kind of data is collected, how this data is used, with whom this information is shared if necessary, what are the rights regarding personal data and how these rights can be used, and the principles adopted regarding confidentiality.

Personal data are processed by AKINER within the scope of the Law On The Protection Of Personal Data No. 6698 (LPPD) in force in Türkiye and in accordance with international general principles, in accordance with the following basic principles:

• Compliance with the law and good faith,
• Being accurate and up to date when necessary,
• Processing for specific, explicit and legitimate purposes,,
• Being relevant, limited and proportionate to the purpose for which they are processed,
• Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Since AKINER provides services in Türkiye and is based in Türkiye, it basically adopts the regulations and principles in the LPPD. In addition, AKINER makes every effort to comply with the European Data Protection Regulation (GDPR) and other legal data protection regulations for persons residing in the European Union or activities in contact with the European Union.

2. Enlightening and Informing the Data Subjects

AKINER is obliged to enlighten/inform the natural persons whose data will be processed during the acquisition of personal data. This Policy aims to provide the necessary information.  In this context, AKINER provides information on the following issues.

• Identity of the data controller and its representative, if any,
• The purpose for which personal data will be processed,
• To whom and for what purpose the processed personal data may be transferred,
• The management and legal reason for collecting personal data and
• Rights of the person concerned.

3. Collection of Personal Data, Collection Method and Legal Reasons

The information that Online Visitors send to the Site while using the Site or accessing a service in any way through the Site, shared through the Site and/or stored in accessible form may fall within the scope of personal data processed under this Policy. Personal data may be collected in writing or electronically through the Site by automatic or non-automatic means.

Usage data – Transaction Security Data: When you access the Site, usage data is collected about you. This may include data about when you visit the Site, what you click on, when you perform these actions, etc. Also, like many websites today, our web servers maintain log files, which record data each time a device accesses them. Log files contain data about the nature of each access, such as source IP addresses, internet service providers, files displayed on your site (e.g. HTML pages, graphics, etc.), operating system versions, general and non-specific location information, internet traffic information device type, system information, and browser type or timestamps. This information may also be processed by means of cookies.  Our information about cookies is below.

For the data subjects visiting AKINER locations; Personal data is collected electronically by automatic means through CCTVs to ensure the security of AKINER workplaces.

Visual Recordings: CCTV recordings

Legal Reasons

The above-mentioned personal data are processed for the purposes specified in this Policy and subject to the online Visitor’s sharing of this data; in accordance with the basic conditions and principles in the LPPD. In this context, Transaction Security is processed in cases where data processing is mandatory in order to fulfill our legal obligations. Other usage data other than Transaction Security data are processed for the reasons that it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract, and that 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 data subject.

For Physical Visitors, the above-mentioned personal data are processed on the grounds that data processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.

4. Purpose of Processing Personal Data

Personal data will be processed for the purposes of collecting and finalizing the requests of the Visitors and thus realizing the purpose of the Site, establishing a contractual relationship with the Visitors and managing all phases of this contractual process, conducting communication activities, conducting/supervising business activities, conducting business continuity activities, conducting service production and operation processes and following up requests and complaints.

The information collected may be used collectively in various ways to provide better service to Visitors, to optimize and improve services, and to enrich the database and improve the service provided to users through this database. The Site may use this information for website management, security, promotional activities, research and analysis. No information collected will be disclosed to the public.

Physical visitor data is processed to ensure physical space security. This data is not disclosed to the public in any way.

5. Transfer of Personal Data

AKINER takes care to process the personal data of Visitors in accordance with the principles of “need to know” and “need to use”, by ensuring the necessary data minimization and taking the necessary technical and administrative security measures. Since the nature of business partnership processes, the requirements of goods and service procurement processes, the execution or supervision of processes such as the management of supply chain management processes, and the operation of digital infrastructures necessitate continuous data flow with different stakeholders, it may be possible to transfer the personal data processed to third party servers.

The personal data of the Visitors may be shared with the service providers providing the IT infrastructure of the Site in line with and limited to the fulfillment of the above-mentioned purposes, with business partners providing services in the field of quality control, complaint management and risk analysis of the services, with the relevant lawyers, auditors and experts within the scope of fulfilling legal obligations, with regulatory and supervisory institutions and competent authorities such as courts and enforcement offices, limited to the purposes specified in this text.

6. Cookies

Cookies are small data files stored on the device you use to access the Site in order to recognize repeat users. Depending on the reason for use, all cookies expire after a certain period of time. Cookies are only used on the Site for the following few reasons:

• Within the limits of legitimate interests regulated in the LPPD in order to make the Site easier to use and to recognize Visitors.
• Security reasons: To verify the identity of the Visitor, for secure access to third party websites accessed by Users through the Site (Google NID cookies, 1P_JAR cookies)
• To be able to offer personalized content if explicitly requested by users: To store certain user preferences (e.g. default language) so that the content shown to Visitors can be personalized.
• To improve the Services; to measure the use of the Site by Visitors, track referral data and show different content to Visitors through direct first-party cookies.
• For links to social networks; when a person explicitly requests to access content directly on a social network through the Site, to enable people to reach the URLs they intend to access.

Regarding the use of cookies, you can block the use of cookies from the section to the left of the URL link when using the Site. However, it should be noted that

The majority of the cookies used on the Site are used for the security and personalized settings of the User. If you disable these cookies, the experience of using the Site may be reduced and you may not be able to access some services effectively.

7. Some of Our Business Partnerships

AKINER’s contents may be displayed on Meta (a family of companies including Facebook and Instagram) or similar online platforms in order to inform Visitors. In such a case, AKINER does not know why and how the relevant content is displayed to the potential data subjects, and cannot access any personal data of these persons (unless shared directly with them). If the data subjects share information directly with AKINER, the rules and principles in this Policy will apply to the relevant information. Different policies prepared for different data processing scenarios of AKINER are separate and independent from this text.

Personal data processed by AKINER transferred through business partners does not make any person identifiable before AKINER. Data that may make the person identifiable are processed by AKINER only in the capacity of data processor. The relevant data are stored for 90 days and deleted at the end of 90 days. AKINER does not transfer this data to any third party and does not carry out any analysis activities based on this data. In a situation where it can benefit from the data in any way, it processes this data by anonymizing it irreversibly. It does not process and host this data in any system in any way that can “identify the person”.

8. Changes and Updates

This Policy may be revised and updated as new features are added to the Site or new suggestions are received from Visitors. However, in this case, the changes will be published on the Site and Visitors will be informed. In some important cases, such changes may be notified by e-mail or other conspicuous method reasonably designed to notify Visitors, with additional notices as appropriate. Upon notification of such changes, if the Visitor continues to access the Site and use the services after the notification period, he/she shall be deemed to have consented to the changes in the Policy. Therefore, we recommend that the Visitor review the Policy each time he/she accesses the Site. If the provisions of the Policy are changed, they become effective on the date of publication.

9. Rights of Data Subjects

Pursuant to Article 11 of the LPPD, the Data Subjects have the following rights;

• To learn whether personal data is being processed,
• To request information if personal data has been processed,
• To learn the purpose of processing personal data and whether they are used for their intended purpose,
• To know the third parties to whom personal data is transferred domestically 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,
• Although it has been processed in accordance with the provisions of the LPPD and other relevant laws, in the event that the reasons requiring its processing disappear, to request the deletion or destruction of personal data within the framework of the conditions stipulated in the LPPD and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
• In the event that the processed data is analyzed exclusively through automated systems and results in a result to the detriment of the Data Subject, to object to this,
• In case the Visitor suffers damage due to the processing of personal data contrary to the LPPD, to demand the compensation of the damage.

Complaints/requests to be made by the Data Subjects whose personal data are processed in order to exercise their rights will be answered and finalized positively/negatively within the shortest possible time and within 30 days at the latest in a reasoned manner.

In the application containing the explanations regarding the right that the Visitor has as a personal data owner and will make in order to exercise the above-mentioned rights and request to exercise the right; the subject matter requested must be clear and understandable, the subject matter requested must be related to his / her person or if the applicant is acting on behalf of someone else, he / she must be specially authorized in this regard and document his / her authority, the application must contain identity and address information and documents certifying the identity must be attached to the application..

Data Controller: Umur Akıner

Address: Cumhuriyet Neighborhood, Halaskargazi Street, No:119/4, Şişli, İstanbul

E-mail: [email protected]