This notice is provided to inform individuals whose personal data is processed through our website, in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and, where applicable, Articles 13–14 of the EU General Data Protection Regulation ("GDPR"). [REQUIRED: confirm target markets and whether GDPR applies]
1. Data Controller
Data controller: [REQUIRED: full legal company name], [REQUIRED: registered address].
Trade registry / MERSIS No.: [REQUIRED] · VERBIS registration status: [REQUIRED]
Contact: contact form
2. Personal Data We Process
The following data is processed through our website:
- Contact form: name / institution, email address, phone number (optional), subject, related product and message content.
- Adverse event / quality complaint form: the reporter's name, institution, contact details, product and lot information and a description of the event. No patient identifiers are requested on this form.
- Security data: a session cookie for form security and an irreversible (hashed) value derived from the IP address to prevent abuse; this value is kept for no more than 10 minutes.
- Analytics data: visit statistics collected via Google Analytics, only if you consent to cookies. See the Cookie Policy for details.
3. Purposes of Processing
- Responding to product information, quote and technical support requests;
- Receiving adverse event and quality complaint reports under medical device regulations and forwarding them to the relevant authorities;
- Ensuring website security and preventing abuse;
- Statistical analysis of website use, where you have consented.
[REQUIRED: confirmation of purposes by legal counsel]
4. Legal Bases
Your personal data is processed on the basis of: processing being directly related to the conclusion or performance of a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)), compliance with the controller's legal obligations (KVKK Art. 5/2(ç); GDPR Art. 6(1)(c)) and legitimate interests (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)); and, for analytics cookies, your explicit consent (KVKK Art. 5/1; GDPR Art. 6(1)(a)).
[REQUIRED: confirmation of legal bases]
5. Transfers of Data
Your personal data may be transferred to competent public authorities under legal obligations (e.g. the Turkish Medicines and Medical Devices Agency), to the manufacturer of the relevant product in the case of adverse event reports, and to our hosting provider.
If you consent to analytics cookies, Google LLC services are used and data may be transferred abroad. [REQUIRED: legal basis for international transfers under KVKK Art. 9 / GDPR Chapter V]
6. Method of Collection and Retention
Data is collected electronically, partly by automated means, through the forms and cookies on our website.
Retention periods: [REQUIRED: retention periods for form submissions and reports]
7. Your Rights
Under KVKK Art. 11 and, where applicable, GDPR Arts. 15–22, you have the right to: learn whether your personal data is processed and request information about it; learn the purpose of processing and whether data is used accordingly; know the third parties to whom data is transferred in Türkiye or abroad; request rectification of incomplete or inaccurate data; request erasure or destruction of your data; request notification of these actions to third parties to whom the data was transferred; object to outcomes against you arising from analysis exclusively by automated systems; request compensation for damage arising from unlawful processing; and, under the GDPR, to data portability, to restrict processing, to withdraw consent at any time and to lodge a complaint with a supervisory authority.
8. How to Apply
You may submit requests regarding your rights in writing, in line with the Communiqué on the Procedures and Principles of Application to the Data Controller, or via our contact form. [REQUIRED: registered electronic mail (KEP) address / application channels]