Privacy Notice Service Provider Representatives

PRIVACY NOTICE

This Privacy Notice has been prepared pursuant to Article 10 of the Personal Data Protection Law No. 6698 ("KVKK") to explain which of your personal data are processed while you use the TreatX Health Platform, for what purposes and on which legal grounds they are processed, to whom and for what reasons they may be transferred, how long they are retained, and how you may exercise your rights under the Law.

1. DATA CONTROLLER

TREATX Medikal Turizm Sanayi ve Ticaret A.Ş. ("TreatX" or the "Company") — MERSİS No.: 0859154003100001 — Address: Adalet Mah. Manas Blv. No: 47B, İç Kapı No: 2809, Bayraklı/İzmir, Türkiye — E-mail: info@treatx.health — Registered Electronic Mail (KEP): treatxmedikal@hs03.kep.tr — Website: www.treatx.health (including its subdomains, the "Platform"). TreatX is the data controller under the Personal Data Protection Law No. 6698 ("KVKK") in respect of the processing activities described in this Notice. For questions concerning the protection of personal data, you may contact our data protection contact point through the channels specified above.

2. SCOPE AND DATA SUBJECTS

This Notice applies to the natural-person representatives and authorised persons, physicians and other healthcare professionals, and employees using the Platform on behalf of healthcare institutions that apply to or register with the Platform as a Service Provider (data subject category: Service Provider representative/employee). When entering its personnel’s data into the Platform, the Service Provider is responsible for informing those individuals.

3. PERSONAL DATA PROCESSED, PURPOSES AND LEGAL GROUNDS

Data category and examples

Purposes of processing

Legal ground (KVKK)

Identity and contact: representative/authorised person’s full name, Turkish ID/passport no. [where verification is required], role/title, corporate e-mail address and telephone number

Conclusion of the Membership Agreement; opening and administration of the account; notifications

Art. 5/2(c)

Professional information: diploma, specialty and employment certificate information, experience, academic title, information to be published on the profile, and photograph

Verification; creation of the profile page within the framework of information permitted under applicable legislation

Art. 5/2(c); Art. 5/2(ç); Art. 5/2(f)

Authorisation and licence: International Health Tourism authorisation certificate, operating permit/licence, signature circular, power-of-attorney information

Verification of compliance with the International Health Tourism Regulation and professional legislation; Platform reliability

Art. 5/2(ç); Art. 5/2(f)

Financial: IBAN, invoicing and tax information

Service Provider settlement payments; commission, set-off and invoicing arrangements

Art. 5/2(c); Art. 5/2(ç)

Usage records: account activity, messaging records, access logs, content publication history

Account security; compliance monitoring under healthcare promotion legislation; record-keeping obligations; evidence in disputes

Art. 5/2(ç); Art. 5/2(e); Art. 5/2(f)

Processing based on Article 5/2(f) of the KVKK is carried out only where the Company has a legitimate interest and provided that such processing does not prejudice your fundamental rights and freedoms.

4. METHOD OF COLLECTION

Data are collected electronically through application forms, the contracting process, the document-upload module, use of the Platform and verification against official records (including verification of authorisation certificates), by fully automated, partially automated and non-automated means.

5. TRANSFERS

Data may be transferred, solely for the purposes set out below, to our suppliers (data processors), business partners, legally authorised public institutions and organisations, and legally authorised private-law persons:

Recipient group

Purpose of transfer

Domestic / international

Payment Institution and banks

Service Provider settlement payments and collection flow

Domestic

Ministry of Health / USHAŞ

Authorisation certificate and audit processes

Domestic

Financial adviser, auditors and legal advisers

Regulatory compliance, books and records, dispute management

Domestic

Hosting and IT suppliers (data processors)

Operation of the infrastructure

Germany, USA

The Company’s group companies / affiliates [if such a structure exists]

Centralised management of finance, accounting and information technology processes

Domestic

Service Recipients

Professional information published on the profile page (only the fields intended for publication)

Countries in which the Platform is accessible

6. RETENTION PERIODS

For evidentiary purposes, data are retained throughout the membership relationship and for the general limitation period of 10 years following its termination; invoice- and tax-related records are retained for the periods prescribed by tax legislation; electronic commerce transaction records are retained for 3 years; and access logs are retained for [1 year]. At the end of the applicable retention periods, the data are destroyed during periodic destruction cycles.

7. DATA SECURITY

Your personal data are protected in accordance with the technical and administrative measures set out in the Board’s guidelines, including encryption in transit and at rest, role-based access controls and an authorisation matrix, multi-factor authentication, maintenance of access logs, regular penetration testing, personnel confidentiality undertakings and awareness training. For special categories of personal data, the adequate measures specified in the Board’s Decision dated 31 January 2018 and numbered 2018/10 are also applied. For further details, please refer to the Security Policy published on the Platform.

8. YOUR RIGHTS AND APPLICATION

Pursuant to Article 11 of the KVKK, by applying to the Company you have the right to:

  • learn whether your personal data are being processed and, if so, request information regarding such processing;
  • learn the purpose of the processing of your personal data and whether they are being used in accordance with that purpose;
  • know the third parties to whom your personal data are transferred in Türkiye or abroad;
  • request correction of your personal data if they have been processed incompletely or inaccurately;
  • request deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK;
  • request notification of the correction and deletion/destruction operations to third parties to whom your personal data have been transferred;
  • object to any outcome against you arising from the analysis of your personal data exclusively by automated systems;
  • claim compensation for damages where you suffer loss as a result of unlawful processing of your personal data.

Application procedure: You may submit your application in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller: (i) through the account/support channel on the Platform, (ii) by completing the [Data Subject Application Form], (iii) in writing to the postal address stated above, (iv) to our registered electronic mail (KEP) address at treatxmedikal@hs03.kep.tr, (v) from the e-mail address registered in our systems to info@treatx.health, or (vi) using a secure electronic signature/mobile signature. Additional verification may be requested to establish your identity. Depending on the nature of your application, it will be concluded free of charge as soon as possible and in any event within 30 (thirty) days at the latest (where the transaction entails an additional cost, the fee set out in the tariff determined by the Board may be charged). If your application is rejected, you find the response insufficient, or no response is provided within the prescribed period, you retain the right to lodge a complaint with the Personal Data Protection Board within 30 days from the date on which you become aware of the response and, in any event, within 60 days from the date of your application (Articles 13–14 of the KVKK).

9. EFFECTIVE DATE AND AMENDMENTS

This Notice entered into force on 2 October 2026. The Company updates this Notice in line with changes to its processing activities; the current version is published on the Platform, and previous versions are archived for evidentiary purposes. [Version: v1.0]

Version
2
Effective from
2026-10-02
Published
2026-10-02
Last updated
2026-10-02
Language
English
What changed
Added Turkish translation and completed multilingual EN/TR version for publication.