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PATIENT PERSONAL DATA PROCESSING CONSENT AND PRIVACY POLICY

ORKEY MEDIKAL TURIZM PAZARLAMA SANAYI VE TICARET LIMITED ŞİRKETI
(hereinafter referred to as POMME BEAUTY TRAVEL AGENCY) hereby presents to your
attention the Information Disclosure and Personal Data Protection Consent, and within the
framework of POMME BEAUTY TRAVEL AGENCY’s Privacy Policy:
For the purpose of providing various advantages to our customers and informing them
accordingly, within the scope of Product marketing processes, analyzing customer shopping
habits and tendencies, and providing personalized offers and segmentation to customers,
customer segmentation based on purchased products, conducting Customer Relationship
Management (CRM) analyses, and managing their execution, executing
Advertising/Communication/Promotion processes and ensuring the sending of electronic
commercial messages (phone, SMS, MMS, e-mail (printed) or other forms), I hereby declare
that my personal data, including special categories of personal data such as Name, Surname,
ID Number, Date of Birth, Gender Information, Email Address, Address Information,
Contact Information, Financial Data, Signature, Visual and Auditory Data, and Camera
recording images taken for Workplace Security purposes, may be processed, used, and
shared, limited to the purpose of processing within the relevant process, and stored for the
required period, and that I have been duly informed about this by reading this text, POMME
BEAUTY TRAVEL AGENCY’s Personal Data Protection and Privacy Policy, and the
Information Disclosure.
PERSONAL DATA PROTECTION POLICY
Your personal data is processed and kept in accordance with the Law on the Protection of
Personal Data No. 6698 (“KVKK”).
1. How Your Personal Data Can Be Processed
In accordance with the Law No. 6698 on the Protection of Personal Data (KVKK), your
personal data shared with POMME BEAUTY TRAVEL AGENCY can be processed in
whole or in part, automatically or non-automatically, by being obtained, recorded, stored,
altered, reorganized, in short, by being processed in any way on the data.
 
 
2. Purposes and Legal Reasons for Processing Your Personal Data
Your personal data shared are processed in compliance with the Law No. 6698 on the
Protection of Personal Data (KVKK) to be able to fulfill the requirements of the services we
provide to our customers, to develop the products and services offered, to provide
information to public authorities in cases related to public security and legal disputes, upon
request and in accordance with the legislation, to offer a wide range of opportunities to our
members or to share these opportunities with legal persons or institutions that can offer them
legally, to analyze advertising preferences in accordance with the Law No. 6698 on the
Protection of Personal Data (KVKK) and related secondary regulations.
3. Information about Third Parties or Institutions to Which Your Personal Data May
Be Transferred
The persons/institutions to whom/which your personal data shared with POMME BEAUTY
TRAVEL AGENCY may be transferred for the above-mentioned purposes are our main
shareholders, our shareholders, advertisers, our direct or indirect domestic/foreign
subsidiaries; organizations with which we have agreements or collaborations, program
partner organizations, domestic/foreign organizations, and other third parties and institutions.
4. Collection Method of Your Personal Data
Your personal data is collected through forms filled out through POMME BEAUTY
TRAVEL AGENCY, containing information such as name, surname, address, phone number,
work or personal email address; preferences on pages accessed using a username and
password, IP records of transactions, cookie data collected by the browser, navigation time,
and details; in the form of location data; from individuals who share their personal data
physically or virtually, face-to-face or remotely, orally or in writing or through electronic
means, for the purposes of establishing a commercial relationship with POMME BEAUTY
TRAVEL AGENCY, applying for a job, submitting a bid, and other methods such as business
cards, resumes (CVs), submitting bids, and the like; also, data obtained indirectly through
various channels, websites, blogs, contests, surveys, games, campaigns, and similar (micro)
websites, and social media, e-newsletter reading or clicking activities, data provided by
public databases, and publicly available profile and data from social sharing sites (Facebook,
Twitter, Google, Instagram, Snapchat, etc.); can be processed and collected.
 
 
5. Transfer of Your Personal Data
Your personal data collected by any of the above-mentioned methods may be transferred to
service providers abroad (countries accredited by the Personal Data Protection Board and
providing sufficient protection for personal data) for processing in Turkey or for processing
and storage outside Turkey, provided that they remain within the scope of the KVKK and for
the purposes of the contract.
Your Personal Data;
may be transferred to our business partners with whom we collaborate and/or from whom we
receive services, authorized authorities who will determine your location in case of an
emergency call, regulatory and supervisory institutions, courts and enforcement offices, and
other public institutions authorized to request your personal data, and legal entities in
commercial relations with POMME BEAUTY TRAVEL AGENCY and who have your
phone number when necessary.
6. Storage and Protection of Personal Data
In accordance with Article 12 of the KVKK, POMME BEAUTY TRAVEL AGENCY is
obliged to prevent the illegal processing of your personal data, prevent unauthorized access,
and ensure their retention, by taking software measures such as hashing, encryption,
processing records, access management, and physical security measures. In case it is learned
that personal data has been obtained by others through illegal means, the situation will be
immediately reported to the Personal Data Protection Board in accordance with legal
regulations and in writing.
*In this statement, we would like to inform you that, except for the situations where the
processing of your personal data is permitted under the KVKK legislation, we will not be
able to provide you with the necessary and sufficient service in terms of processes requiring
the explicit consent of your personal data, including your special categories of personal data,
if you do not accept the consent statement. We also want to inform you that our Company’s
commercial and operational activities will be adversely affected.
1. CONFIDENTIAL INFORMATION
1.1. Confidential Information is defined as all data, samples, technical and economic
information, commercialization, research strategy, invention, including all information,
including trade secrets, that is not disclosed to the public and will be disclosed to the Parties
as part of their contact or agreement.
 
 
1.2. Confidential Information includes, without limitation, the following:
● All information, ideas, estimates disclosed to the other party in connection with the
purpose, whether written or oral;
● All information exchanged orally or in writing between the Parties, discussions,
conversations, or meetings, and verbal exchanges of all information;
● All analyses, compilations, works, offers, and other documents prepared by both
parties;
● All commercial agreements or agreements concluded between the parties, contracts
containing confidential information exchange.
1.3. However, each of the Parties may fully or partially disclose or use Confidential
Information in the following cases:
● If the disclosure of confidential information becomes public due to a breach or fault
other than this agreement;
● If the disclosing party gives written consent to the free transmission or use of the
confidential information by third parties;
● If the receiving party can prove that it had the said information before it was disclosed
by the other party;
● If one of the Parties is obliged to disclose it by a decision of the competent court or
official or administrative authority, or by the current law or regulation; for this
purpose, it is necessary to notify the other party within a reasonable time frame
allowing it to apply for an appropriate protective interim measure before the
disclosure, provided that all necessary legal and reasonable measures to prevent such
disclosure have been taken and the information has been registered in favor of the
disclosing party.
1.4. Furthermore, all data that may be exchanged between the parties, which include
information that will protect the identity of the person who owns them and, without
limitation, all data that will be protected under the Law No. 6698 on the Protection of
Personal Data and that will not limit the protection of the person who is subject to the law,
will be considered confidential information, and the provisions of the relevant law will be
complied with to keep this information confidential. Your personal data, which you share
with us and which we request and share with us as the Data Controller, limited and
proportionate to the purpose and duration of processing under the Law No. 6698 on the
Protection of Personal Data (“KVKK”), will be recorded, stored, kept, rearranged, and may
 
 
be processed in other ways listed in the KVKK, shared with competent institutions authorized
to request these personal data, and stored in connection with the purpose of processing. In
accordance with the KVKK, your personal data may be processed, transferred to third parties
in Turkey, stored, used for profiling, and classified in line with our service purposes, legal
obligations, and the collection method, purpose, and legal reason for processing. Again, this
contract aims to inform you about your rights under the KVKK.
2. OBLIGATIONS REGARDING CONFIDENTIALITY
2.1. By signing this Agreement, each of the Parties undertakes to keep all Confidential
information strictly private and confidential, to consider it as a duty of secrecy, to take all
necessary measures to ensure and maintain confidentiality, to prevent its disclosure to any
third party except employees other than those who disclose confidential information, and to
exercise due diligence. This Agreement is prepared to determine the exchange method of
confidential information to be disclosed by the Parties to each other during their negotiations
and to determine the rights and obligations within the scope of the Law on the Protection of
Personal Data (“KVKK”) regarding the protection of Confidential Information. The data
controller must comply with principles in processing personal data. These are: compliance
with the law and honesty rules, being accurate and up-to-date when necessary, being
processed for specific, clear, and legitimate purposes, being processed limitedly and
proportionately to the purpose for which they are processed, being stored for the period
stipulated by the relevant legislation or for the duration required for the purpose of
processing.
2.2. In addition, each of the Parties explicitly states in this Agreement that:
a) They undertake not to use Confidential Information for any purpose, directly or
indirectly, for their own or any third party’s benefit, other than for the purpose
permitted by the disclosing Party;
b) They undertake not to disclose, report, publish, or disclose any Confidential
Information to any third party, company, agency, or institution, or to avoid such
disclosure by any means whatsoever (except as stated in (c)) and to take all necessary
legal or other measures to prevent such disclosure.
c) They undertake to disclose Confidential Information to employees, agents, or
representatives only on a strict “need to know” basis, subject to the condition that they
be subject to obligations no less strict than those set forth in this Agreement, with the
express written consent of the disclosing Party.
d) Your personal data will be stored in accordance with the purpose of storage, limited,
and proportionate to the Law No. 6698 on the Protection of Personal Data (“KVKK”).
 
 
In accordance with the KVKK, your personal data may be processed, transferred to
third parties in Turkey, stored, used for profiling, and classified in line with our
service purposes, legal obligations, and the collection method, purpose, and legal
reason for processing.
3. COPYING OF CONFIDENTIAL INFORMATION
Each of the Parties explicitly undertakes that Confidential Information will not be copied in
whole or in part without the prior written consent of the relevant party.
4. RETURN OF CONFIDENTIAL INFORMATION
4.1. Each of the Parties agrees, without prejudice to other obligations, that they are bound by
the following obligations under this Agreement when the Agreement terminates:
All documents containing Confidential Information will be returned to the party owning this
information or to other persons indicated by this party.
Copies of such documents and reports, compilations, analyses, and comments prepared by
employees or representatives specified in paragraph 2.2 above, or on behalf of or for them,
will be destroyed.
Copies stored on the computer where Confidential Information is recorded or held by the
party receiving the confidential information or its representatives, or by the persons specified
in paragraph 2.2 above, will be deleted.
In the event of termination or termination of the relationship based on this agreement for any
reason, the personal data of individuals will be deleted, destroyed, or anonymized by the data
controller in accordance with Article 7 of the Law No. 6698 on the Protection of Personal
Data (“KVKK”).
5. INDEMNITY
5.1. Each of the Parties acknowledges that in the event of a breach of any of the obligations
imposed on them by this Agreement, despite the return of the Confidential Information, the
other party may suffer significant damage solely due to the breach of the obligations
mentioned above. Therefore, each of the parties undertakes to indemnify the other party for
such damages in proportion to their fault.
 
 
5.2. Each of the Parties acknowledges that they have the right to prevent any threat to
confidentiality or to stop the violation of ongoing confidentiality by legal means, and in case
a decision is obtained against the violating party, the violating party agrees to indemnify the
other party for all legal expenses and costs, including attorney’s fees.
5.3. According to the KVKK, the data controller holding personal data must take necessary
care in protecting these data. Otherwise, it is obliged to compensate for the damages suffered
by the affected party.
6. CONFIDENTIALITY OF TRANSACTIONS AND
NEGOTIATIONS
6.1. Transactions and the contents of this Agreement and negotiations to be conducted will be
kept strictly confidential.
6.2. Regarding public announcements, the relevant Parties will decide mutually.
6.3. The Parties will protect and preserve personal data in accordance with Article 12 of the
KVKK, preventing unlawful processing and access to these personal data. The data controller
may also process personal data in accordance with the obligation to inform and explicit
consent.
7. TERM
7.1. This Agreement will enter into force on the date of signature. The Parties have agreed
and declared that they are obliged to keep each other’s “Confidential Information”
confidential indefinitely, even if the subject matter of this agreement has ended.
If this Agreement is terminated or expires as specified herein, all information and documents
and copies thereof in the possession of the other Party, belonging to the disclosing Party, will
be returned or destroyed upon the request of the disclosing Party.
In accordance with Article 7 of the KVKK, the data controller will delete, destroy, or
anonymize personal data when the purpose of processing the data ceases to exist.
 
 
8. COMPETENT COURT
8.1. All disputes, claims, and conflicts arising from this Agreement will be under the
jurisdiction of Istanbul Anatolian Courts and Enforcement Offices.
9. NOTIFICATIONS
9.1. All notifications under this Agreement will be made in writing in one of the following
ways:
a) Sent by courier or registered mail to the notification addresses of the parties below;
b) Sent by fax or email, and confirmed by courier or registered mail. In this case,
notifications will be deemed to have been received on a date not later than the date
indicated on the signed mail receipt at the address.
10. MISCELLANEOUS PROVISIONS
10.1. Each of the Parties declares and undertakes that the information disclosed to each other
under this Agreement is complete and accurate. The Party breaching this obligation under this
paragraph will indemnify the other Party for any damage and loss incurred.
10.2. No reference or addition shall be made to the provisions of this Agreement without a
written agreement.
10.3. The commitments contained in this Agreement are binding on the companies and
groups directly or indirectly controlled by the Parties, as well as their agents and successors.
This agreement, consisting of 2 copies, has been signed to enter into force on the specified
date.
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ORKEY MEDIKAL TURIZM PAZARLAMA SANAYI VE TICARET LIMITED ŞİRKETI
(Tax ID: 6470739420)
Patient Name Surname:
ID – Passport Number:
Signature: