Law on Protection of Personal Data Information

PERSONAL DATA STORAGE, DESTRUCTION, AND ANONYMIZATION POLICY

1. PURPOSE:

As MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş, we place great importance on the protection of personal data belonging to all individuals we come into contact with while carrying out our commercial activities, and on fulfilling the requirements stated in the Law on the Protection of Personal Data No. 6698 ("KVKK" or "Law") in full since the date it came into effect.

This Personal Data Storage, Destruction, and Anonymization Policy ("Policy") has been prepared to inform you about the principles and processes for the collection, use, sharing, storage, deletion, destruction, and anonymization of personal data by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş.

This Policy outlines the principles regarding the processing of personal data belonging to data subjects by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş, in line with the sequence of regulations stated in the KVKK. These explanations cover the employees, active and potential patients/customers, visitors, and other real persons in relation to MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş.

In accordance with the regulations, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş, as a Data Controller required to register in the Registry, is obligated to store personal data in compliance with the personal data inventory and to prepare a Policy to delete, destroy or anonymize it when necessary, and to act in accordance with this Policy.

The following principles will apply in the storage and destruction of personal data:

  • The general principles in Article 4 of the Law will be adhered to.
  • MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş acknowledges that preparing this Policy alone does not mean that personal data is deleted, destroyed, or anonymized in accordance with the Regulation, Law, and relevant legislation.
  • MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş commits to acting in accordance with the security measures stated in Article 12 of the Law, relevant provisions in the legislation, decisions of the Personal Data Protection Board, and this Policy when storing or deleting, destroying, or anonymizing personal data.
  • MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş guarantees compliance with this Policy and the associated tools, programs, and processes during the deletion, destruction, or anonymization of personal data processed automatically or non-automatically as part of any data recording system.

2. SCOPE

This Policy applies to all processes of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş.

3. DEFINITIONS

Law: The Law on the Protection of Personal Data No. 6698.

Regulation: The Regulation on the Deletion, Destruction, or Anonymization of Personal Data.

Board: The Personal Data Protection Board.

Recording Environment: Any environment where personal data processed automatically, partially automatically, or non-automatically as part of any data recording system is stored.

Personal Data Processing Inventory: The inventory created and detailed by data controllers by associating personal data processing activities with personal data processing purposes, data category, recipient group to whom data is transferred, and the group of data subjects, based on the data controllers' business processes.

Destruction: The deletion, destruction, or anonymization of personal data.

Periodic Destruction: The process of deleting, destroying, or anonymizing personal data at repeated intervals specified in the personal data storage and destruction policy, in cases where all conditions for processing personal data stated in the Law no longer exist.

Registry: The Data Controllers Registry held by the Presidency. Data-Recording System: The recording system in which personal data is processed according to certain criteria.

Data Controller: The real or legal person who determines the purposes and means of processing personal data, establishes and manages the data recording system.

Recipient Group: The category of real or legal persons to whom personal data is transferred by the data controller.

Relevant User: Persons who process personal data within the organization of the data controller or under the authority and instructions received from the data controller, excluding the person or unit responsible for the technical storage, protection, and backup of data.

The definitions in the Personal Data Protection Policy also apply to this Policy.

4. REFERENCES

The Law on the Protection of Personal Data No. 6698, the Regulation on the Deletion, Destruction, or Anonymization of Personal Data, the Regulation on the Data Controllers Registry, and other relevant regulations.

5. PROCEDURES AND PRINCIPLES REGARDING THE PROTECTION OF PERSONAL DATA

5.1. GENERAL PRINCIPLES FOR PROCESSING

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş processes personal data in accordance with the procedures and principles stipulated in the KVKK and other relevant laws. In this context, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş fully complies with the following principles when processing personal data as stated in the KVKK.

Lawfulness and conformity with the rules of bona fides: In accordance with this principle, the data processing processes of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş are carried out within the limits required by all relevant legislation, including the Constitution and the KVKK, as well as the rules of bona fides.

Being accurate and up-to-date when necessary: Necessary measures are taken to ensure that personal data processed by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş is accurate and up-to-date, and data subjects are provided with the necessary opportunities to ensure that the data processed reflects the real situation.

Processing for specified, explicit, and legitimate purposes: MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş processes personal data only for clearly and definitively specified legitimate purposes and does not carry out data processing activities beyond these purposes. In this context, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş processes personal data only if it is related to and necessary for the establishment of a business relationship with data subjects.

Being relevant, limited, and proportionate to the purposes for which they are processed: MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş processes data in compliance with the KVKK and other relevant legislation, suitable for achieving the purposes specified for data categories, related to the purpose, and proportionate, and avoids processing personal data that is not needed.

Retaining for the period stipulated in the relevant legislation or required for the purpose for which they are processed: MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş retains personal data processed only for the period stipulated in the relevant legislation or required for the purpose for which they are processed. In this context, if there is a period specified in the relevant legislation for the retention of data, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş complies with this period; if there is no such period, data is retained only for the period necessary for the purpose for which it is processed.

5.2. CONDITIONS FOR PROCESSING PERSONAL DATA

The conditions for processing personal data are regulated by the KVKK, and personal data is processed by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş in accordance with these conditions. Except for the exceptions stated in the Law, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş processes personal data only by obtaining the explicit consent of the data subjects. In cases where the following conditions stated in the Law exist, personal data may be processed even if the data subject's explicit consent is not obtained.

Explicitly stipulated by law

It is mandatory for the protection of the life or bodily integrity of the person or another person who is unable to express their consent due to actual impossibility or whose consent is not legally valid,

It is necessary to process personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.

It is mandatory for the data controller to fulfill their legal obligation,

The data subject has made their personal data public themselves,

It is mandatory for the establishment, exercise, or protection of a right

It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

In the processing of special categories of personal data, which are considered more critical to be protected from various perspectives, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş shows special sensitivity.

In this context, provided that sufficient measures determined by the Board are taken, such data is not processed without the explicit consent of the data subjects. However, special categories of personal data other than those related to health and sexual life may be processed without the explicit consent of the data subject in cases stipulated by law.

On the other hand, personal data related to health and sexual life may be processed without the explicit consent of the data subject provided that sufficient measures are taken and the following reasons exist:

  • Protection of public health,
  • Preventive medicine,
  • Medical diagnosis,
  • Execution of treatment and care services
  • Planning and management of health services and financing.
5.3. PURPOSES OF PROCESSING PERSONAL DATA

Your personal data obtained by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş can be processed within the scopes explained below.

  • Creating personnel files, payroll,
  • Managing employee contract processes,
  • Executing insurance renewal processes,
  • Providing health services to employees,
  • Maintaining blood group lists,
  • Allocating vehicles, phones, and lines to employees within the scope of the employment contract,
  • Managing power of attorney and signature circular processes,
  • Preparing and executing emergency plans and operations,
  • Managing occupational health and safety processes,
  • Structuring service procurement contract processes,
  • Planning, auditing, and executing information security processes,
  • Opening and authorizing email accounts for employees,
  • Maintaining internet log records,
  • Planning and executing corporate communication activities,
  • Managing document processes and follow-up,
  • Issuing cards and service records for personnel entries,
  • Providing and managing personnel training,
  • Planning and executing in-house training and orientation programs,
  • In-house operations,
  • Legal, technical, and administrative outcome activities,
  • Strategy, planning, and partner/supplier management,
  • Planning and executing corporate communication activities and events,
  • Patient management processes
  • Managing cookie information
  • Social media management
  • Advertising, promotion, and campaign processes
  • Managing suggestion and complaint processes
  • Fulfilling obligations arising from legislation such as the Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages

The categories mentioned above are for informational purposes, and other categories may be added by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş to carry out its future commercial and operational activities.

In such cases, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will continue to update the specified categories for you in the relevant texts to keep you informed as quickly as possible.

5.4. STORAGE OF PERSONAL DATA

Your personal data is securely stored in physical or electronic environments for the durations stipulated in the relevant legislation.

5.5. TRANSFER OF PERSONAL DATA TO DOMESTIC PARTIES

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş carefully complies with the conditions regulated in the KVKK for sharing personal data with third parties, without prejudice to the provisions of other laws. In this context, personal data is not transferred to third parties without the explicit consent of the data subject by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş. However, in the presence of one of the following conditions regulated by the KVKK, personal data may be transferred by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş without obtaining the explicit consent of the data subject.

Explicitly stipulated by law

It is mandatory for the protection of the life or bodily integrity of the person or another person who is unable to express their consent due to actual impossibility or whose consent is not legally valid,

It is necessary to process personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.

It is mandatory for the data controller to fulfill their legal obligation,

The data subject has made their personal data public themselves,

It is mandatory for the establishment, exercise, or protection of a right

It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Provided that sufficient measures are taken; in the case of special categories of personal data other than those related to health and sexual life, if stipulated by law, and in the case of special categories of personal data related to health and sexual life,

For the protection of public health,

Preventive medicine, medical diagnosis,

Execution of treatment and care services, compliance with legal and regulatory requirements, and planning and management of health services and financing, personal data may be transferred without obtaining the explicit consent of the data subject.

In the transfer of special categories of personal data, the conditions specified in the processing of such data are also complied with.

5.6. TRANSFER OF PERSONAL DATA ABROAD

For the transfer of personal data abroad, the explicit consent of the data subject is sought in accordance with Article 9 of the KVKK. However, in cases where it is permitted to process personal data, including special categories of personal data, without obtaining the explicit consent of the data subject, personal data may be transferred abroad by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş without obtaining the explicit consent of the data subject, provided that sufficient protection is provided in the foreign country where the personal data will be transferred. If the country to which the transfer will be made is not determined by the Board among the countries with sufficient protection, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş and the relevant data controller/data processor in the foreign country will undertake sufficient protection in writing.

5.7. YOUR RIGHTS PURSUANT TO ARTICLE 11 OF THE LAW ON THE PROTECTION OF PERSONAL DATA NO. 6698

By applying to our company, you have the right to

  1. Learn whether your personal data is processed or not,
  2. Request information if your personal data has been processed,
  3. Learn the purpose of processing your personal data and whether it is used in accordance with the purpose,
  4. Know the third parties to whom personal data is transferred domestically or abroad,
  5. Request the correction of your personal data if it is incomplete or incorrectly processed,
  6. Request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law,
  7. Request the notification of the operations carried out pursuant to subparagraphs (e) and (f) to third parties to whom personal data is transferred,
  8. Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
  9. Request compensation for the damage in case of loss due to unlawful processing of personal data.

Data subjects can use the above-mentioned rights by sending a wet-signed copy of the data subject application form found in Annex 1 of this Policy to the contact addresses of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş by mail, email, or registered mail. Detailed information on filling out and sending the form to MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş is included in the application form in Annex 1.

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will deliver the response to relevant applications physically or electronically to the relevant data subject. MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will conclude the request free of charge as soon as possible and within no later than thirty (30) days depending on the nature of the request. However, if the transaction incurs an additional cost, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will charge the fee determined in the tariff specified by the Board to the relevant parties.

Additionally, in the process of finalizing the requests of data subjects, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş may request additional information or documents from the applicants.

5.8. MEASURES TAKEN FOR DATA SECURITY

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş takes all necessary technical and administrative measures to ensure the appropriate level of security for the protection of personal data. The measures stipulated in Article 12(1) of the KVKK are as follows:

  • Preventing the unlawful processing of personal data,
  • Preventing the unlawful access to personal data,
  • Ensuring the preservation of personal data
5.9. PROCESSING OF VIDEO RECORDINGS

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş, in order to ensure the general and commercial security of its clinic facilities and operations, processes video recordings of visitors, employees, and other relevant persons in accordance with the principles outlined in the KVKK and this Policy, and stores these recordings securely in physical or electronic environments for the duration suitable for the purposes of processing.

In places where video recording is taken, warnings indicating that video recording is being taken are visibly placed to inform data subjects. MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş complies with all obligations stipulated in the relevant legislation, especially the KVKK, in relation to the protection of personal data during these activities.

No video recording is taken in places with high privacy.

6. DELETION, DESTRUCTION, OR ANONYMIZATION OF YOUR PERSONAL DATA

Your personal data processed for the purposes stated in this Personal Data Protection Policy will be deleted, destroyed, or anonymized by us when the purpose requiring processing disappears and the periods determined by laws expire, in accordance with Article 7/1 of Law No. 6698.

6.1. Deletion of Personal Data

The deletion of personal data processed automatically or partially automatically means that such personal data becomes inaccessible and unusable by relevant users in any way. The data controller explains how the conditions stated in the third paragraph are met in its policies and procedures to consider personal data deleted. The deletion of personal data processed non-automatically as part of any data recording system;

The process of anonymizing unnecessary personal data in paper form, scanned or digitally transferred to electronic media, will be carried out by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş in cases where it processes data completely or automatically, and MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş must ensure that data is inaccessible or unusable in any way. When deleting data, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş must guarantee that data is inaccessible or unusable by any user. This guarantee is under the responsibility of the data controller.

If personal data that should not be deleted is affected by the deletion and becomes inaccessible and/or unusable, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will consider the following methods, which can be applied together with the decision of the KVKK Working Group, as deletion.

  1. Archiving personal data in a way that it cannot be associated with the relevant person,
  2. Closing all access to personal data,
  3. Taking all necessary technical and administrative measures to ensure that personal data is accessed only by authorized persons when necessary,
  4. Updating the methods of deletion according to the Regulation in relevant cases is the responsibility of the Data Controller.
6.2. DESTRUCTION OF PERSONAL DATA

The destruction process will be carried out by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş when it processes data in physical recording environments. MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş is obligated to make this data unrecoverable. During these processes, employees and relevant departments of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş are required to notify the KVKK Working Group about the data to be destroyed, and afterward, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will take all necessary technical and administrative measures.

6.3. ANONYMIZATION OF PERSONAL DATA

The anonymization process involves making personal data processed by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş completely or automatically unidentifiable even if matched with other data.

Anonymizing personal data is the responsibility of the data subject business unit within MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş. The data subject business unit can seek support from different departments of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş, provided that it controls the destruction of the data itself.

During the anonymization of data, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş may use methods such as one-way functions and encryption. In cases where the accuracy of the method to be applied cannot be ensured, the KVKK Working Group should be consulted.

7. METHODS AND PROCESS OF DESTRUCTION OF PERSONAL DATA

For the destruction of personal data, MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş defines all the methods that can be used during destruction in this Policy. The data subject business unit is responsible for selecting and applying the appropriate method from this Policy according to the relevant situation.

During the destruction of personal data, employees of MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş perform the destruction using one of the following methods:

7.1. Overwriting

The process of writing random data consisting of at least 8 times of 0s and 1s on magnetic media and rewritable optical media with software to make the old data unreadable.

7.2. Degaussing

The process of making the data on magnetic media unreadable by subjecting it to physical changes in a high-value magnetic field.

7.3. Physical Destruction

The process of physically destroying optical media or magnetic media by melting, pulverizing, grinding, and similar methods. It can be applied in cases where degaussing or overwriting methods fail.

7.4. Cloud Destruction

The process of notifying the agreed service provider about the destruction of personal data stored in cloud systems, followed by the destruction of all copies of encryption keys.

7.5. Destruction of Personal Data in Peripheral Systems

The destruction process for personal data stored in devices such as printers, fingerprint units, and door entry turnstiles. If there is an internal unit, or if there is no internal unit, the entire device must be destroyed using the methods of overwriting, degaussing, or physical destruction. Such destruction must be performed before the devices undergo backup, maintenance, and similar procedures.

8. RETENTION AND DESTRUCTION PERIODS

8.1. Periodic Destruction and Legal Retention Periods

Data that has fulfilled its legal retention and destruction periods is periodically destroyed. MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş deletes, destroys, or anonymizes personal data in the first periodic destruction process following the date when the obligation to delete, destroy, or anonymize arises. Periodic destruction is carried out every 6 months for all personal data. Actions related to the deletion, destruction, and anonymization of data are kept for at least 3 years, excluding other legal obligations.

8.2. Deletion and Destruction Process Upon Request of Data Subjects

In cases where data subjects request the deletion or destruction of their personal data by applying to our company, the processing conditions of the personal data are checked, and relevant actions are taken accordingly. If all the conditions for processing personal data have disappeared, the personal data subject to the request is deleted, destroyed, or anonymized. Our clinic concludes the request of the relevant person within a maximum of thirty days and informs the relevant person.

If all the conditions for processing personal data have disappeared and the personal data subject to the request has been transferred to third parties, the data controller notifies the third party of this situation; ensures that the necessary actions are taken under the Regulation by the third party.

If all the conditions for processing personal data have not disappeared, our clinic may reject the request of the relevant data subject by explaining the reason and notify the rejection in writing or electronically within a maximum of thirty days.

9. CHANGES TO THE POLICY

9.1.

After any official changes in the relevant legislation, changes can be made to this Policy by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş to comply with these changes.

9.2

MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş will update the Policy to reflect the changes made and will share the updated Policy with its employees via email and make it accessible to its employees through the corporate website www.medicantalya.com.

EFFECTIVENESS This Policy prepared by MEDIC ANTALYA MEDİKAL ÖZEL AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ A.Ş came into effect on 01.07.2022.

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