General Clarification Text on the Processing of Personal Data

Identity of the Data Controller

We, as BMK Gözeten Sağlık Hizmetleri A.Ş. (Laura Dental Center), place great importance on the security of your personal data and respect your privacy. In this regard, we inform you about the conditions under which all your personal data are obtained, how they are processed, our sensitivity in protecting them, and your rights concerning these personal data within the scope of the Personal Data Protection Law No. 6698 (“Law”).

Definitions

In this clarification text:

• Personal Data: Any information relating to an identified or identifiable natural person.

• Data Subject: The natural person whose personal data is processed.

• Personal Data Protection Law (“KVKK”): The Personal Data Protection Law No. 6698, which was published in the Official Gazette on April 7, 2016, and entered into force.

• Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.

• Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

The processing of personal data refers to any operation performed on data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data. In accordance with Law No. 6698, any information that makes your identity specific or identifiable is considered “Personal Data” and may be processed by Laura Dental Center as the Data Controller within the scope of the above definition.

All personal health data necessary for the execution of all medical diagnosis, examination, treatment, and care services, as well as the primary general and special categories of personal data obtained for this purpose, are listed below:

• Identity Data: Name, surname, Turkish ID number, or if you are not a Turkish citizen, your passport number or temporary Turkish ID number, place and date of birth, marital status, gender, etc., and personal data obtained through the ID card or similar identification document you provide.

• Contact Data: Address, phone number, email address, etc.

• Financial Data: Bank account number, IBAN number, etc.

• Health Data: Laboratory and imaging results, test results, examination data, prescription information, and other health and sexual life-related data obtained during the execution of medical diagnosis, treatment, and care services, as well as responses and comments you share to evaluate our services.

• Digital Data: Video and audio recordings taken during your visit to our facilities, and voice call recordings if you contact our call center.

• Other: Data related to your private health insurance and Social Security Institution for the financing and planning of your health services; browsing information, IP address, browser information obtained during your use of our website and mobile application; and medical documents, surveys, form information, and location data you provide voluntarily.

Your personal data are processed, recorded, transferred, shared, and stored as described below and within the limits set by official legislation.

Collection of Your Personal Data

Your personal data are collected for various reasons, primarily in accordance with the relevant regulations and legislation in the following laws:

• 1982 Constitution of the Republic of Turkey

• Turkish Penal Code No. 5237

• Decree Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliates

• Personal Data Protection Law No. 6698

• Fundamental Law on Health Services No. 3359

• Regulation on Private Hospitals

• Regulation on the Processing of Personal Health Data and Protection of Privacy

• Law No. 3071 on the Use of the Right to Petition

• Law No. 4982 on the Right to Information

• Law No. 5236 on Misdemeanors

• Regulations of the Ministry of Health and other legislative provisions.

Additionally, as stated in Article 6/3 of the Law, personal data related to health and sexual life may be processed without the explicit consent of the individual only by persons or authorized institutions and organizations under the obligation of confidentiality, for purposes such as protecting public health, preventive medicine, medical diagnosis, treatment and care services, and planning and management of health services and financing.

Your personal data are collected through various channels, including but not limited to:

• Forms you fill out on our website or mobile applications

• Information you provide during your visits to our clinic

• Data obtained during phone calls with our call center

• Information you provide via email or other communication methods

• Data obtained through agreements or other documents you sign with our clinic

• Information obtained through third parties such as insurance companies or health institutions

Purposes of Processing Your Personal Data

Your personal data are processed for the following purposes:

• Planning and managing health services and financing

• Providing medical diagnosis, treatment, and care services

• Complying with legal and regulatory requirements

• Managing patient relations and providing information to patients

• Conducting risk management and quality improvement activities

• Conducting research and analysis to improve our services

• Billing and financial transactions

• Planning and executing corporate communication and promotional activities

• Ensuring the security of our facilities, patients,