KVKK Clarification Text
KVKK Clarification Text
As Dr. Senai Aksoy (the “Data Controller”), we pay maximum attention to the security of your personal data. With this awareness, we attach great importance to the processing and preservation of all personal data belonging to persons associated with our clinic in accordance with the Law on Protection of Personal Data No. 6698 (the “KVKK”).
1. Purposes of Processing Personal Data
Your personal data is processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK for the following purposes:
- Carrying out medical diagnosis, treatment, and care services.
- Managing health services and financing.
- Informing you about your appointments.
- Complying with legal and regulatory requirements.
- Identity verification.
2. To Whom and for What Purposes the Processed Personal Data Can Be Transferred
Your personal data may be transferred to:
- Ministry of Health, Provincial Health Directorates, and other authorized public institutions and organizations.
- Your designated representatives or lawyers.
- Third-party service providers (labs, hospitals) that we collaborate with for your treatment.
When marketing cookies are accepted, hashed identifiers may be transferred to the following recipients outside Türkiye, as described in sections 6 and 7:
- Google LLC (United States) — see section 6
- Meta Platforms, Inc. (United States) and Meta Platforms Ireland Limited (Ireland) — see section 7
- Cloudflare, Inc. (United States) — edge worker infrastructure that performs server-side hashing for section 7; plaintext is held in worker memory only for milliseconds during hashing and is not written to disk, storage, or logs
3. Method and Legal Reason for Collecting Personal Data
Your personal data is collected by our clinic through various channels (forms, website, telephone, etc.) for the legal reasons stated above and to fulfill our obligations arising from contracts and the law.
4. Rights of the Personal Data Subject
According to Article 11 of the KVKK, you have the following rights:
- To learn whether your personal data is processed.
- To request information if your personal data has been processed.
- To learn the purpose of processing your personal data and whether they are used in accordance with their purpose.
- To know the third parties to whom your personal data is transferred domestically or abroad.
- To request correction of your personal data if it is incomplete or incorrectly processed.
- To request the deletion or destruction of your personal data.
- To object to any result occurring against you by analyzing the processed data exclusively through automated systems.
5. Contact Information
To exercise your rights, you can send your request to our clinic at the following address:
Dr. Senai Aksoy Address: Lotus Nisantasi, Halaskargazi, Halaskargazi Cd. No: 38-66, Kat: 5, Office 92 34371 Sisli / Istanbul, Türkiye Email: [email protected]
6. Marketing Attribution / EC for Leads
When you submit a contact form with marketing cookies accepted, your email address, phone number, and name are processed locally in your browser using SHA-256 one-way hashing and stored in browser localStorage for up to 90 days. The hashed values are transmitted to Google LLC (United States) each time you trigger a conversion event (form submission or WhatsApp contact click) while your marketing consent remains active, exclusively to measure the effectiveness of our advertising campaigns. Legal basis: your explicit consent via the cookie banner (KVKK Art. 5/1; GDPR Art. 6(1)(a)). You may withdraw consent at any time using “Manage cookies”; on withdrawal, locally stored hashed identifiers are deleted from your browser immediately.
7. Marketing Attribution Data Processing (Meta Pixel + Conversions API)
When you submit a contact form or click a WhatsApp deeplink on our website with marketing cookies accepted, two parallel data flows are triggered:
- Meta Pixel (browser-side): Meta’s automatic advanced-matching feature hashes your email address and phone number locally in your browser using SHA-256 (a one-way cryptographic transformation that cannot be reversed) and transmits the hashes directly to Meta Platforms, Inc. (United States).
- Meta Conversions API (server-side): The same event is mirrored through our Cloudflare Worker (
tag.draksoyivf.com). Your email and phone are briefly held in worker memory (milliseconds), hashed using SHA-256, and the hashes — together with your IP address and user-agent — are forwarded to Meta Platforms, Inc. The plaintext values are not written to disk, storage, or logs.
Meta uses these hashed identifiers exclusively to measure the effectiveness of our advertising campaigns and to build aggregate audience insights. Individual identities are not revealed to us in any matching result.
Legal basis: Your explicit consent (KVKK Article 5/1; GDPR Article 6(1)(a) for users in EU jurisdictions), provided by accepting the “Marketing” category in our cookie consent banner. The same consent toggle also covers Google Ads Enhanced Conversions for Leads (Section 6) — both integrations share a single consent gate.
Data recipients:
- Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States (primary)
- Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin, Ireland (EU operations backup)
- Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, United States (edge worker infrastructure; processes plaintext for milliseconds during hashing, then drops it)
Cross-border transfers to the United States are performed under Meta’s Data Processing Terms (https://www.facebook.com/legal/terms/dataprocessingterms) and Cloudflare’s Data Processing Addendum (https://www.cloudflare.com/cloudflare-customer-dpa/), both incorporating standard contractual clauses approved under KVKK Article 9.
Your rights: You may withdraw your consent at any time by clicking “Manage cookies” at the bottom of this page and disabling the “Marketing” category. Withdrawal is effective immediately for future visits. Hashed identifiers already transmitted to Meta cannot be deleted by us as they cannot be reversed to your identity; their retention by Meta is governed by Meta’s published retention policies (https://www.facebook.com/policy.php). Local-storage entries are purged after 90 days even without explicit withdrawal.
For users in Saudi Arabia, the United Arab Emirates, Kuwait, Algeria, or Morocco: Additional rights and disclosures may apply under your local data protection law (KSA PDPL, UAE Federal Decree-Law No. 45/2021, Algeria Loi 18-07, Morocco Loi 09-08). Contact us at [email protected] to exercise jurisdiction-specific rights.
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