Sante Privee

Personal Data Protection and Privacy Policy

Last updated: [September, 2025]

1. Introduction and Purpose

At Sante Privee, we respect your privacy and are deeply committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information in accordance with the Turkish Law on Protection of Personal Data (KVKK) No. 6698 and the EU General Data Protection Regulation (GDPR).

By using our website (www.santeprivee.tr) and related services, you consent to the practices described in this policy, acknowledging that you have been duly informed and are providing your explicit consent where required.

2. Categories of Personal Data We Collect and Legal Basis

We may collect the following categories of personal data. We process your data based on legal grounds explicitly stipulated in the relevant legislation or those necessary for the provision of services:

Data CategoryExample DataLegal Basis (KVKK/GDPR)
Identity & Contact InformationName, surname, email, phone number, address.Performance of a contract, legitimate interest of the data controller.
Special Categories of Personal Data (Health)Health history, medical reports, medical images/photos (with explicit consent).Explicit Consent, and for the purposes of preventive medicine, medical diagnosis, treatment, and care services (public health).
Travel InformationPassport details, flight and accommodation preferences.Necessity for the performance of a contract.
Technical DataIP address, browser type, device information, cookies.Legitimate interest of the data controller.

Special Note: Your Special Categories of Personal Data, such as health data, will be processed strictly by authorized healthcare professionals who are under an obligation of secrecy, and only for the purposes of medical diagnosis, treatment, and care services, in line with your explicit consent.

3. Purposes of Processing Personal Data

Your personal data may be processed for the following specific purposes:

  • To provide free medical consultation and prepare a personalized treatment plan.

  • To organize travel, transfer, and accommodation services as part of the treatment package.

  • To coordinate services with partner hospitals, clinics, and licensed physicians.

  • To ensure the performance of the service contract and carry out invoicing procedures.

  • To comply with legal obligations and health regulations (e.g., licensing, supervision).

  • To improve our website and services through analytics.

4. Data Sharing and International Transfers

We may share your personal data with the following third parties, only to fulfill the purposes mentioned above and in compliance with applicable laws:

  • Partner hospitals, clinics, and licensed healthcare providers (for treatment execution).

  • Travel and accommodation service providers (for reservation and transfer operations).

  • Authorized public institutions and organizations, if legally required.

Data may be transferred outside of Turkey when necessary and in compliance with GDPR and KVKK safeguards, such as to countries providing adequate protection or where appropriate legal guarantees (e.g., standard contractual clauses) are applied.

5. Data Retention Period

We retain personal data only for as long as necessary to fulfill the service’s purpose or as required by legal obligations:

  • Medical Records (Health Data): Up to 20 years as required by relevant legislation.

  • Other Personal Data: Up to 10 years after the termination of the service contract.

After these periods, your data will be securely deleted, destroyed, or anonymized.

6. Your Rights as a Data Subject

Under Article 11 of the KVKK and GDPR, you have the right to:

  • Learn whether your personal data is being processed and request access to it.

  • Request the rectification, erasure (right to be forgotten), or restriction of processing of your data.

  • Object to processing and the right to withdraw your consent.

  • Request data portability.

To exercise these rights, please contact us in writing at info@santeprivee.tr or by using a secure electronic signature/mobile signature. Your requests will be concluded within a maximum of 30 days in accordance with the KVKK.

7. Security Measures

We implement technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse. These measures include encryption, access controls, up-to-date security software, and secure servers.

8. Updates to This Policy

We may update this Privacy Policy from time to time. Changes will be published on our website along with the updated date.

9. Contact Us

For questions regarding this Privacy Policy or to exercise your rights, please contact us at:

  • Email: info@santeprivee.tr

  • Phone: +90 546 299 79 19

  • Data Controller Representative: [M. Burak SEZER]

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