Privacy Notice

Website Privacy and Personal Data Processing Notice

Effective date: 18 August 2026
Version: 1.0

1. Data Controller

This Privacy Notice is issued by:

Legal name: DRSMİLE AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ LİMİTED ŞİRKETİ
Trading name: Dr Smile Antalya
Address: Meydankavağı Mah., Avni Tolunay Cad., C Blok No:53, Muratpaşa, Antalya, Türkiye
MERSIS No.: 0313135043400001
Tax ID: 3131350434
Tax Office: Antalya Kurumlar
Website: https://www.drsmileantalya.com
Email: info@drsmileantalya.com
Registered Electronic Mail (KEP): drsmile@hs01.kep.tr
Telephone/WhatsApp: +90 545 213 09 09
International Health Tourism Authorisation Certificate: ST-3601

DRSMİLE AĞIZ VE DİŞ SAĞLIĞI HİZMETLERİ LİMİTED ŞİRKETİ is referred to in this notice as “Dr Smile Antalya”, “the Clinic”, “we”, “us” or “our”.

2. Purpose and Scope

This Privacy Notice explains how we collect, use, store, transfer and protect personal data obtained through our website, online enquiry and consultation forms, email, telephone, WhatsApp, meet-up registrations and related digital communications.

We process personal data in accordance with Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and other applicable Turkish legislation.

Where our activities fall within their territorial scope, we also apply the relevant transparency and data-subject standards of the UK GDPR and/or EU GDPR.

This notice provides information only. It is not an agreement and does not request consent. Where consent is required for a particular processing activity, it will be requested separately through a specific and unticked consent option.

3. Personal Data We May Collect

Depending on how you interact with us, we may collect:

Identity and contact data

Your name and surname, telephone number, email address, country, preferred language and preferred communication method.

Enquiry and communication data

Your messages, treatment interests, questions, appointment preferences, meet-up registration information and communication history.

Health and clinical data

Where you voluntarily provide them, we may process dental photographs, X-rays, oral and dental health information, medical history, medication, allergies, previous treatments and other information relevant to a preliminary assessment.

Health information and medical documents are special-category personal data.

Uploaded content

Files, photographs, X-rays and documents that you intentionally upload or send to us.

Please do not send passport copies, payment-card details or unrelated medical documents through a general website form.

Appointment and travel-support data

Requested appointment dates, arrival information, transfer details and accommodation preferences where you ask us to coordinate these services.

Technical and usage data

Your IP address, device and browser information, approximate location, referral source, security logs, cookie identifiers and cookie-consent choices.

Communication and consent records

Form submissions, email and WhatsApp communications, call records where legally permitted, the version of the notice presented to you, consent date and time, selected consent options and withdrawal records.

4. How We Collect Personal Data

We collect personal data directly from you when you:

Browse our website;
Complete an enquiry or consultation form;
Upload a photograph, X-ray or document;
Contact us by email, telephone or WhatsApp;
Register for a meet-up;
Request an online preliminary assessment;
Communicate with a dentist or patient coordinator.

We may also receive limited technical data from service providers that help us operate and secure the website, deliver communications or measure website usage after the required consent has been obtained.

5. Why We Process Personal Data

We may process personal data for the following purposes:

Responding to enquiries and communication requests;
Arranging consultations, appointments and meet-ups;
Conducting an online preliminary dental assessment;
Discussing possible treatment options;
Preparing an indicative treatment discussion;
Coordinating requested transfer or travel-support services;
Establishing and managing a patient relationship;
Maintaining clinical and administrative records;
Protecting patient safety and service quality;
Securing the website and preventing fraud or misuse;
Complying with healthcare, tax, consumer and other legal obligations;
Establishing, exercising or defending legal claims;
Measuring website performance after analytics consent;
Measuring advertising performance after marketing-cookie consent.

6. Legal Grounds for Processing

Depending on the processing activity, we may rely on:

Processing being necessary to respond to your request or take steps before entering into a service relationship;
Processing being necessary for the performance of a contract;
Compliance with a legal obligation;
Processing being necessary for the establishment, exercise or protection of a legal right;
Our legitimate interests, provided that your fundamental rights and freedoms are not overridden;
Your explicit consent where legally required;
An applicable condition under Article 6 of the KVKK for the processing of special-category personal data.

Health data may be processed without explicit consent where processing is lawfully required for medical diagnosis, treatment, care or the management of health services and is performed by persons or organisations subject to confidentiality obligations.

Where another lawful processing condition applies, we will not request unnecessary consent.

7. Online Preliminary Assessments

Information submitted online is used to support an initial discussion. It does not by itself constitute:

A final diagnosis;
A definitive treatment plan;
Confirmation of treatment suitability;
A guarantee of treatment duration;
A guarantee of results.

A definitive assessment requires an examination by an authorised dental professional and, where appropriate, diagnostic imaging.

You may submit a general enquiry without providing health data. If you choose to upload photographs, X-rays or medical information, the relevant health-data information and any required explicit-consent option must be presented before submission.

8. Cookies and Similar Technologies

Strictly necessary technologies may operate to provide website security, essential functions and storage of your cookie choices.

Analytics, advertising and other non-essential technologies are not activated until you make the relevant choice.

Further information is available in our Cookie Policy and Cookie Settings panel.

9. Recipients of Personal Data

Personal data may be disclosed, only where necessary, to:

Authorised dentists and healthcare professionals;
Patient coordinators and authorised administrative personnel;
Website, hosting, email and technical-support providers;
Cybersecurity, backup and consent-management providers;
Dental laboratories and medical suppliers;
Other healthcare providers involved in a requested consultation or treatment;
Transfer, accommodation or travel-support providers where you request coordination;
Accountants, auditors, insurers and legal advisers;
Authorised public institutions and regulatory bodies;
Communication and platform providers selected by you, including Google services and Meta/WhatsApp.

Each recipient receives only the data reasonably necessary for the relevant purpose.

10. International Data Transfers

Some technology, communications, cloud, analytics and platform providers may store personal data outside Türkiye or make it accessible from abroad.

Where an international transfer takes place, we use an applicable transfer mechanism under Article 9 of the KVKK, including:

An adequacy basis where available;
An appropriate safeguard;
An applicable standard contract;
Another legally permitted transfer mechanism;
Explicit consent where it is the legal basis relied upon.

If explicit consent is required for an international transfer, it is requested separately.

If you initiate contact through WhatsApp, Google or another third-party platform, that provider also processes information under its own privacy terms.

Alternative contact methods are available through email, telephone, written application and KEP.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for applicable statutory, medical-record, tax, consumer, limitation and legal-claims periods.

Enquiries that do not lead to treatment are periodically reviewed and deleted or anonymised when no longer required.

Clinical records created after treatment begins are retained for the periods required by applicable healthcare legislation and the Clinic’s retention schedule.

Consent and withdrawal records may be retained for the period necessary to demonstrate compliance and resolve potential disputes.

When a retention period ends, personal data is securely deleted, destroyed or anonymised.

12. Data Security

We apply proportionate administrative and technical safeguards, including:

Access controls and role-based permissions;
Confidentiality obligations;
Secure transmission where available;
System and security logging;
Backup and recovery controls;
Malware and abuse protection;
Supplier and service-provider reviews;
Staff training and awareness measures.

No internet transmission is completely risk-free. Please use the designated secure route for sensitive documents and do not send unnecessary personal information.

13. Your Rights

Under Article 11 of the KVKK, you may:

Ask whether your personal data is being processed;
Request information about the processing;
Learn the purpose of processing;
Learn whether the data is used in accordance with its stated purpose;
Learn the recipients to whom data has been transferred in Türkiye or abroad;
Request correction of incomplete or inaccurate data;
Request deletion or destruction where the legal conditions are met;
Request notification of correction, deletion or destruction to recipients;
Object to an adverse outcome resulting exclusively from automated analysis;
Claim compensation for damage caused by unlawful processing.

Where the UK GDPR or EU GDPR applies, you may also have rights to access, rectification, erasure, restriction, objection, data portability, withdrawal of consent and complaint to the competent supervisory authority, subject to applicable conditions and exemptions.

14. How to Exercise Your Rights

Your request should identify you, describe the right you wish to exercise and include sufficient information to locate the relevant records.

You may apply:

In writing to: Meydankavağı Mah., Avni Tolunay Cad., C Blok No:53, Muratpaşa, Antalya, Türkiye;
By KEP to: drsmile@hs01.kep.tr;
From an email address previously notified to and registered with the Clinic to: info@drsmileantalya.com;
Through another application method permitted by applicable law.

Applications are handled free of charge unless a fee is permitted under the applicable tariff.

We aim to respond as soon as possible and no later than thirty days under the KVKK, subject to identity verification and the nature of the request.

15. Children and Minors

The website is not designed to collect health data directly from children without the involvement of a parent or lawful guardian.

A parent or guardian should make the enquiry and provide any legally required authorisation for a minor.

16. Automated Decision-Making

The website and any information assistant are not authorised to diagnose, determine treatment suitability or make final clinical decisions.

We do not make legally or similarly significant decisions about patients solely by automated means.

17. Third-Party Websites

Our website may contain links to social networks, review platforms, maps, messaging services and other third-party websites.

These services process personal data under their own privacy policies. We are not responsible for the independent privacy practices of third-party websites.

18. Changes to This Notice

We may update this notice when our services, technology or legal obligations change.

The current version and effective date will be displayed on our website.

For questions about this Privacy Notice, contact:

Email: info@drsmileantalya.com
KEP: drsmile@hs01.kep.tr
Telephone: +90 545 213 09 09