THE HEART DOCTRINE CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA ("Clarification Text")

Last Updated Date: 13 May 2024

The Heart Doctrine – Can Üstünbaş ("Company"), acting in the capacity of Data Controller, carries out the process of secure processing and protection of your personal data with sensitivity. The Company has prepared this clarification text in order to enlighten the persons ("Data Subject") whose personal data are processed in the capacity of "data controller" within the scope of the Personal Data Protection Law No. 6698 ("KVKK"). The Company fulfills its obligations regarding the collection, deletion, destruction, anonymization, transfer of your personal data, informing the Data Subjects and ensuring data security within the scope of the provisions of KVKK.

This Clarification Text has been prepared and submitted to you in order to inform you that your personal data will be processed and stored in accordance with the law and to fulfill the data controller's obligation to inform you within the scope of KVKK in case you use ("User") our website ’www.theheartdoctrine.com’’ ("Website"). This Clarification Text is shared with you in order to ensure that the Company duly fulfills its obligations under Article 10 of the KVKK titled "Data Controller's Obligation to Inform".

The Company, with the full understanding of the responsibility imposed on it within the scope of KVKK, processes your personal data as described below and within the limits stipulated in the legislation, in the capacity of "Data Controller" defined in KVKK.

WHO IS THE DATA CONTROLLER?

The data controller is defined as the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

Identity of the Data Controller

PURPOSES AND LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA

This Clarification Text explains the collection methods and legal reasons of your personal data, which of your personal data is processed in case you use the Website and Application as a User, for what purposes personal data is used, to whom and for what purposes personal data can be transferred, deletion, destruction and anonymization of personal data, the rights of the Data Subjects on their personal data and how these rights can be exercised.

Your personal data are processed by automatic or non-automatic methods, in writing or electronically through the Website and/or Application, in accordance with Articles 5 and 6 of the KVKK, for the legitimate interests of the Data Controller and in this context, for the legitimate interests of the Data Controller and in order to fully and completely fulfill the responsibilities arising from the contract and laws, provided that it is directly related to the establishment or performance of a contract, provided that it is directly related to the establishment or performance of a contract, or provided that it does not harm the fundamental rights and freedoms of the person concerned.

Your Processed Personal Data and Collection Methods

Your personal data specified in categories below are collected by the Company through electronic media via the Website channels.

The Company may transfer your personal data to third-parties in Turkey and abroad for the above-mentioned purposes and in accordance with Article 8 of the KVKK, subject to obtaining your explicit consent.

The Company, may transfer your personal data mentioned above;

• To the relevant public institutions and organizations in order to fulfill our legal obligations,
• In order to ensure our legitimate interest and to provide uninterrupted, safe and quality service, to subcontractors, third-parties from whom we receive services and our business partners from whom we receive services.

In case you have your explicit consent, the Company may process and transfer the aforementioned personal data in line with the aforementioned data processing purposes in accordance with the relevant legal reason.

In order to ensure the security of your personal data transferred in question, administrative and technical measures such as transmission through secure channels, encryption, keeping access records, logging are applied and data protection and (confidentiality) agreements are made with the third-parties to whom the transfer is made.

Erasure, Destruction and Anonymization of Personal Data

Your personal data collected for the purposes and legal reasons described above will be processed in confidentiality by applying the protection measures specified in the KVKK. Your personal data will be processed for the period required by our company's purpose of processing that data and for the period stipulated in the relevant legislation and will be deleted, destroyed or anonymized for statistical purposes when the processing period expires.

Your Rights Arising from the Law on the Protection of Personal Data

To learn about your personal data in accordance with the KVKK by applying to our Company;

• To learn whether your personal data is processed or not, and if processed, to request information about it,
• Learn the purpose of processing and whether it is used in accordance with its purpose,
• Knowing the third-parties to whom it is transferred domestically or abroad,
• To request correction in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third-parties to whom personal data is transferred,
• Although it has been processed in accordance with the provisions of the KVKK and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to notify the third-parties to whom the personal data is transferred in this context,
• To object to the occurrence of a result to the detriment of the person himself/herself by analyzing it exclusively through automated systems (e.g. voice recording, website cookies, malware, etc.),
• In case of damage due to unlawful processing, to demand the compensation of the damage incurred.

If the applications to be made for these purposes require an additional cost, you may be required to pay the fee amount in the fee schedule to be determined by the Personal Data Protection Board. Your requests in your application will be finalized as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

Rights regarding personal data can only be exercised with respect to the data belonging to the individuals themselves.

Pursuant to paragraph 1 of Article 13 of the KVKK, you can submit your requests to our Company in writing or by other methods determined by the Personal Data Protection Board. In this context, the channels and procedures for your applications to our Company within the scope of Article 11 of the KVKK in writing or by using KEP are listed below.

How to Contact Us

In case you have any questions, comments or requests regarding this Explicit Consent Text or the processing of your personal data, together with the documents showing your identity in accordance with the procedures and principles in the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356;

• You can always apply to our address 100.Yıl Mahallesi Umurbey sokak 5/2 G.O.P Çankaya/Ankara- 06700 with your inked signature.
• You can send an electronical mail to our address “info@theheartdoctrine.com”

The requests in your application will be evaluated and finalized as soon as possible and within 30 days at the latest. Our company reserves the right to charge a fee over the fee rate (if any) determined by the Personal Data Protection Board regarding the requests.

Updates

This Clarification Text may be updated from time to time in order to adapt to changing conditions and legislation.

By reading this Clarification Text, you agree that you have been informed about the processing of your personal data.

You can contact us for any questions, requests and opinions regarding your personal data.