Personal Data Processing Information/Notice
Your personal data is processed by TURASSIST Sağlık Destek Hizmetleri A.Ş. (“the Company” or “we”) in accordance with the Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the 'PDPL') and the secondary legislation deriving its legal basis, as well as decisions of the Personal Data Protection Board (hereinafter referred to as the 'Board') and other relevant legislation. The collection, storage, transfer, or any processing of your personal data by the Company and data processors authorized by the Company (hereinafter referred to as the “Business Partners”) within the scope of a contractual relationship and with confidentiality obligations are outlined within the framework of this document.
For What Purposes Do We Process Your Data?
Your personal data is processed in compliance with the procedures and principles prescribed by the PDPL for the fulfillment of obligations specified by the relevant legislation, especially the Insurance Legislation, including but not limited to the establishment and performance of insurance contracts, including claims processes. Within this context, personal data at the Company is processed for the following purposes:
- Execution of candidate applications and placement processes and establishment of employment contracts,
- Performance of employment contracts concluded with employees, management of employee satisfaction and commitment processes, fulfillment of obligations arising from the employment contract and legislation, and management of additional rights and benefits for employees,
- Conducting our company's business operations, our business relations, and human resources processes,
- Carrying out processes related to support service providers within the scope of insurance contract performance,
- Providing services under insurance contracts to third parties in the capacity of policyholders or stakeholders, or making payments,
- Establishment of contracts between the Company and real person brokers, agents, and actuaries with whom a partnership is made for the establishment of the insurance contract and the performance of services in case of damage,
- Provision of assistance services,
- Management of relationships with business partners and/or suppliers, contract, and business process management,
- Conducting communication activities,
- Conducting processes within the scope of agency application and agency contracts,
- Creation of policy proposals, issuance of policies, presentation of policy renewal proposals, and processing of policy cancellation transactions,
- Conducting financial and accounting operations,
- Calculation of insurance compensations, payment to the insured or beneficiaries, and pursuit of recourse,
- Making recourse claims to insurance companies and third parties and tracking these claims,
- Follow-up of unsettled damage files,
- Execution of procedures related to premium collection,
- Preparation of damage files and settlement of damage payments,
- Preparation of expert and appraisal reports, and performance tracking of experts,
- Conducting reinsurance and co-insurance processes,
- Evaluation and response to recourse claims transmitted by insurance companies and third parties,
- Creation and tracking of visitor records,
- Evaluation of customer requests and complaints,
- Conducting customer satisfaction surveys and interviews,
- Conducting marketing, advertising, and campaign processes,
- Conducting legal transactions and processes,
- Providing information to authorized institutions and organizations in accordance with the relevant legislation,
- Planning and conducting internal audit activities necessary for the conduct of activities in accordance with the Company's procedures and relevant legislation,
- Conducting processes arising from Corporate Law,
- Managing risk assessment processes in accordance with Insurance Legislation.
You will be further informed in a clearer manner within the scope of the relevant service if required by the legislation on why this information is collected and how it will be used.
Processing of Sensitive Personal Data
Our company conducts its activities in accordance with Data Protection Legislation and the Regulation on Personal Health Data, regarding the processing of sensitive personal data. The processing of sensitive personal data without the explicit consent of the data subject is prohibited except for the exceptional cases specified in Article 6, Paragraph 3 of the Law on the Protection of Personal Data (KVKK).
Processing of Personal Health Data
Personal health data may be processed if one of the following conditions exists, subject to taking the necessary precautions as prescribed by the Personal Data Protection Board, compliance with general principles, and the obligation of confidentiality:
- The explicit written consent of the data subject, or
- Preservation of public health,
- Preventive medicine,
- Conducting medical diagnosis, treatment, and care services,
- Planning and management of health services financing.
Processing of Special Categories of Personal Data Excluding Health and Sexual Life
Data falling within this scope may be processed if the explicit consent of the data subjecrt exists or in cases envisaged by the laws.
Who Do We Share Your Personal Data With and How?
Your personal data may be shared with our contracted institutions, services, your policy's relevant agency (list of contracted institutions, services, agencies we have agreements with), call centers, assistance services, and companies from whom we receive services for actuarial calculations, primarily for the effective conduct of our activities and the fulfillment of obligations arising from insurance contracts. In these shares, care is taken to limit the shared personal data to the service provided.
The Company may share the personal data it collects with third parties that may be of interest to you regarding direct marketing activities to help determine products and services offered by these third parties according to your preferences.
By law, without the need for notification or explicit consent, we may use your personal data to prevent crime and fraud and to monitor and/or ensure the Company's compliance with the law.
Your personal data is shared with these parties or our affiliated companies for the purposes of policy issuance, determination of insurance premiums (including claim processes), management of your requests, renewal proposal, reinsurance of risks, co-insurance, verifying your identity, preventing misuse, and establishing and protecting rights.
By law, without the need for notification or explicit consent, we may share your personal data with official authorities (such as the Turkish Prime Ministry Undersecretariat of Treasury).
Your personal data may be disclosed in the presence of any of the following conditions:
- As required by the legislation;
- To ensure the security of our employees, the public, or the Company;
- To fulfill an adjudication, court order, or legal process;
- In the case of a merger, asset sale, or similar transactions.
To conduct our activities (e.g., managing information systems and storage, data analysis, etc.), we may disclose your personal data to third-party service providers.
However, unless stated otherwise, as long as you do not opt out of receiving direct marketing messages, we may share your personal data with third parties that assist us in market research and marketing campaigns.
Transfer of Data Abroad
In accordance with the Data Protection Legislation, for the purposes of storage, administration, financial and internal audits, your personal data may be transferred to third parties and institutions located abroad, limited to data storage service providers and our company shareholders. Your personal data will be safeguarded adequately in these transfers. Your personal data will not be transferred to any other third party outside these parties.
- Pursuant to Article 9 of the KVKK Law, for the transfer of personal data abroad, one of the following conditions is required in addition to fulfilling the conditions for domestic transfers: The country to which the transfer will be made must be among the countries declared to have sufficient protection by the Personal Data Protection Board or if there is no adequate protection in the country of transfer, data controllers in Turkey and the relevant foreign country must provide adequate protection in writing, and the permission of the Personal Data Protection Board must be obtained.
How and for What Legal Reasons Do We Collect and Process Personal Data About You?
Collection of Personal Data Provided Directly by You:
The Company collects the following personal data provided by you through digital channels such as call centers, internet sites, and intermediaries:
- Basic personal information such as your name, ID number, address, email address, phone number, and date of birth;
- Payment and credit card information;
- Special category personal data – in certain situations, your health data or previously provided (for the purpose of determining damage assessments) explanations regarding your criminal convictions;
- Information about your relatives or family;
- Your marketing and communication preferences.
- Regarding personal data related to third parties provided by you (for example, a family member or a customer), it is your responsibility to provide and verify the following:
(i) Informing the relevant individual about who the Company is and how we use personal information (as described in this Privacy Notice); and
(ii) Obtaining the consent of the relevant individual to process their personal data (including special category personal data) by us as described in this Privacy Notice.
Collection of Personal Data Regarding You by Third Parties:
We obtain some of the personal data we collect legally from credit institutions, services, agents (authorized institutions, services, agents we have agreements with), the Company's partner institutions and organizations, domestic/foreign banks, brokers, reinsurance companies, the Insurance and Reinsurance Companies Union of Turkey, and official institutions such as the Turkish Prime Ministry Undersecretariat of Treasury.
This personal data can be used to evaluate an application for a product, service, or price quote, verify your identity, prevent misuse, and carry out your transactions, providing special premium and payment options for you.
In cases required by the legislation during the processing of personal data within the framework of individual procedures, we will inform you separately and/or request your permission.
Legal Basis for the Collection and Processing of Personal Data:
Your personal data processed by us will be evaluated for each specific situation under one of the following legal bases:
- Explicitly prescribed by law,
- Necessary to protect the life or bodily integrity of the data subject or another person in cases where consent cannot be given by the data subject or consent is not legally valid,
- Necessary for the conclusion or performance of a contract directly related to the parties to the contract,
- Necessary for compliance with a legal obligation,
- Made public by the data subject,
- Necessary for the establishment, exercise, or protection of a right,
- Necessary for our legitimate interests provided that it does not harm your fundamental rights and freedoms, or
- Obtaining explicit consent when necessary and within these limits and by taking necessary precautions.
Deletion, Destruction, and Anonymization of Personal Data
According to Article 7 of the KVKK Law, even if personal data have been processed in accordance with the relevant legislation, personal data will be deleted, destroyed, or anonymized by the Company ex officio or upon the request of the data subject when the reasons requiring the processing have disappeared. The implementation regarding this issue will be carried out in accordance with the Data Protection Legislation.
Your Right to Apply Regarding Personal Data
Under Article 11 of the KVKK Law, everyone whose personal data is processed can apply to our company and make requests related to the following issues:
- Learning whether personal data is processed,
- Requesting information if personal data has been processed,
- Learning the purpose of processing personal data and whether they are used in line with this purpose,
- Learning the third parties to whom personal data are transferred domestically or abroad,
- Requesting the correction of incomplete or incorrect personal data and requesting notification to third parties to whom this data was transferred within this scope,
- Requesting the deletion, destruction, or anonymization of personal data when the reasons requiring the processing cease to exist, and requesting notification to third parties to whom this data was transferred within this scope,
- Objecting to the occurrence of a result against the data subject by exclusively analyzing processed data through automated systems,
- Requesting compensation for damages in case of suffering damage due to the illegal processing of personal data.
In this context, your requests must be in writing in accordance with Data Protection Legislation.
Therefore, you can download the application form for the Law on the Protection of Personal Data from here, fill it out, and send it to the Company via email using the contact information below.
**Security of Your Personal