ESTEGRANDE

Personal Data Protection and Processing Policy

1. Introduction

EsteGrande places the utmost importance on the protection of fundamental rights and freedoms, particularly the right to privacy, in accordance with the Turkish Law on the Protection of Personal Data No. 6698 (“KVKK”) and the European Union General Data Protection Regulation (“GDPR”).

Ensuring the security of personal data is a primary objective of EsteGrande. Administrative and technical measures are implemented to prevent unlawful processing, unauthorized access, or data breaches.

1.1 Purpose of the Policy

The purpose of this Policy is to inform data subjects about the procedures and principles followed by EsteGrande regarding the protection and processing of personal data.

1.2 Scope of the Policy

This Policy applies to Patients/Clients, Employees, Job Applicants, and Visitors who are natural persons. It does not apply to legal entities.

1.3 Definitions

Explicit Consent: Freely given, informed consent related to a specific matter.

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

Processing of Personal Data: Any operation performed on personal data.

Data Controller: EsteGrande.

2. Protection of Personal Data

EsteGrande implements appropriate technical and organizational measures to ensure data security in accordance with KVKK and GDPR.

3. Processing and Transfer of Personal Data

Personal data are processed lawfully, fairly, transparently, and for legitimate purposes.

4. Data Collection Methods and Legal Grounds

Personal data are collected through physical and electronic means based on KVKK and GDPR.

5. Rights of Data Subjects

Data subjects have the right to access, rectify, erase, restrict processing, and object to processing under applicable legislation.