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HemorrhoidsAnal FissureAnal FistulaPilonidal SinusGenital WartsRectal BleedingPerianal AbscessHidradenitisRectal Prolapse
About UsPatient ReviewsOur MissionOur DoctorsIn the PressAvrupa TVRate UsContracted InstitutionsPatient Rights
HemorrhoidsAnal FistulaAnal FissureHidradenitis SuppurativaPilonidal SinusGenital WartsRectal bleedingAnal ItchingRectal ProlapseAnal AestheticsPerianal AbscessAnal Polyp
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About Us

As Avrupa Cerrahi, we understand what health means and how valuable it is. Since 2005, we have remained committed to delivering high-standard healthcare step by step.

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+90 552 608 39 21

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Home/Privacy Policy and Personal Data Protection Notice

Privacy Policy and Personal Data Protection Notice

How Avrupa Cerrahi processes and protects the personal and health data of its patients, including international patients, under KVKK and the GDPR.

Table of Contents

  1. 1.1. Data controller
  2. 2.2. Who this notice covers
  3. 3.3. Personal data we process
  4. 4.4. Purposes for which we process your data
  5. 5.5. Legal grounds
  6. 6.6. With whom we share your data
  7. 7.7. Transfers abroad
  8. 8.8. How we protect your data
  9. 9.9. How long we keep your data
  10. 10.10. Cookies
  11. 11.11. Your rights
  12. 12.12. Applications
  13. 13.13. Changes

Last updated: October 2, 2026

Last updated: 2 October 2026

This notice explains how your personal data is processed in the course of the healthcare services provided by Avrupa Cerrahi Sağlık Merkezi Ltd. Şti. It covers our patients living in Türkiye as well as patients who come from abroad for treatment and their relatives. It has been prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK). For our patients living in the European Economic Area, the rights arising under the European Union General Data Protection Regulation (GDPR) are also set out separately.

1. Data controller

Avrupa Cerrahi Sağlık Merkezi Ltd. Şti.
Levent Mahallesi, Levent Caddesi No:4, 34330 Beşiktaş / İstanbul, Türkiye
E-mail: info@avrupacerrahi.net

2. Who this notice covers

  • Visitors to our websites (avrupacerrahi.com.tr and avrupacerrahi.net),
  • Persons who contact us through forms, by telephone, via WhatsApp or by e-mail,
  • Patients examined and treated at our clinic,
  • International patients who come to Türkiye for treatment and the relatives accompanying them (companions),
  • Patients referred to us through an intermediary agency or an insurance company.

3. Personal data we process

  • Identity: first name, surname, date of birth, sex, nationality; for foreign nationals, passport or identity document details.
  • Contact: telephone, e-mail, address, country, preferred language of communication.
  • Health data: your complaints, medical history, the photographs, test results and reports you send us, examination findings, diagnosis, treatment and surgery information, medications you take, discharge and follow-up records.
  • Travel and accommodation: information such as arrival and departure dates, flight details, place of accommodation and airport transfer. This information is processed only when you request these services from us.
  • Financial: billing information, payment records and, where applicable, insurance or pre-authorisation information.
  • Communication records: your correspondence with us and call centre conversations. Telephone calls may be recorded for service quality purposes and to ensure that your request is followed up correctly.
  • Website use: IP address, browser and device information, cookie data (details in Section 10).

4. Purposes for which we process your data

  • To receive your enquiry, get back to you and schedule appointments,
  • To carry out a preliminary medical assessment based on the information and documents you send and to explain the treatment options to you,
  • To provide examination, diagnosis, treatment, surgery and care services,
  • To provide interpreting support for our international patients and, if you request it, to coordinate accommodation and transfer arrangements,
  • To carry out post-discharge check-ups and remote follow-up consultations and, where necessary, to share information with your doctor in your country (such sharing takes place only at your request),
  • To carry out billing, payment and, where applicable, insurance processes,
  • To fulfil our record-keeping and reporting obligations under healthcare legislation,
  • To receive and evaluate your opinions, suggestions, complaints and satisfaction feedback, and to improve our service,
  • To ensure information security and patient safety, and to protect our rights in legal disputes.

We obtain your separate consent before sending you campaign or promotional messages. Not giving this consent does not affect your access to healthcare services.

5. Legal grounds

We process your personal data under Article 5 of the KVKK on the following legal grounds: the conclusion and performance of the healthcare services contract with you, compliance with our legal obligations, the establishment, exercise or protection of a right, and our legitimate interest, provided that this does not harm your fundamental rights.

Your health data is special category personal data. Under Article 6 of the KVKK, we process this data for the purpose of providing medical diagnosis, treatment and care services, and only through physicians, healthcare staff and authorised persons who are bound by a duty of confidentiality. For processing outside this scope (for example, sharing your health data with an intermediary agency other than at your request), we obtain your explicit consent.

For our patients living in the European Economic Area, the relevant GDPR provisions are: performance of a contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c)), legitimate interests (Art. 6(1)(f)), medical diagnosis and treatment for health data (Art. 9(2)(h)) and, where necessary, explicit consent (Art. 6(1)(a) and Art. 9(2)(a)).

6. With whom we share your data

Your data is shared only to the extent necessary for the purpose and only with the following recipients:

  • Competent public authorities: authorised institutions and organisations, in particular the Ministry of Health and its affiliated systems, for the records and notifications required by law.
  • Healthcare service partners: the laboratories and imaging centres we work with for your tests.
  • Insurance companies: where you wish your treatment to be covered by insurance.
  • Intermediary agencies: if you reached us through a health tourism intermediary agency, the information necessary to coordinate your treatment plan may be shared with that agency. Your health data is shared with that agency only with your explicit consent.
  • Interpreters: interpreters who provide you with language support during consultations and treatment. Our interpreters are bound by a duty of confidentiality.
  • Accommodation and transfer providers: only when you request this service, and only your name, contact and travel details. Your health data is not shared with these companies.
  • Our service providers: companies providing website, form, e-mail, communication and information technology infrastructure; our accounting and legal advisers.
  • Persons you designate: your doctor in your country or a relative you wish to be informed, only at your request.

7. Transfers abroad

Our websites and patient records are kept on servers in Türkiye. However, some of our service providers have servers abroad. For example, enquiries submitted through web forms are processed on a US-based customer relationship management (CRM) platform, and e-mails are processed by an international e-mail service. Website traffic passes through a content delivery network (CDN). Analytics and advertising cookies run only if you have consented to cookies. If you choose to write to us through a messaging application such as WhatsApp, your correspondence is processed on that application's infrastructure.

We carry out these transfers in accordance with Article 9 of the KVKK: by signing standard contracts and notifying the Personal Data Protection Authority, or on the basis of the other safeguards or exceptions listed in the law. Transfers made at your request to your own physician or insurance company in your home country also fall within this scope.

8. How we protect your data

The main measures we take to protect the confidentiality and privacy of patient data and to protect it against unauthorised access are as follows:

  • Authorisation-based access: only the physicians, healthcare staff and authorised employees directly involved in your treatment can access your health data, and only to the extent their duties require.
  • Access logs: our patient record system logs who accessed which record, when, and what they changed.
  • Encrypted communication: our websites and forms operate only over encrypted (HTTPS/TLS) connections.
  • System security: our servers are protected by a firewall. Login attempts are limited, security updates are applied regularly and data is backed up regularly.
  • Duty of confidentiality: our employees, interpreters and business partners with access to patient data are bound by a duty of confidentiality. Our employees receive training on personal data protection and patient privacy.
  • Privacy during examination and treatment: examinations and consultations take place in closed rooms, and printed documents are kept where unauthorised persons cannot access them.
  • Data minimisation: we ask only for the data necessary for the purpose. We share with business partners only the information that the task in question requires.
  • Breach notification: if your data is obtained by unauthorised persons, we notify the Personal Data Protection Board (KVKK Board) as soon as possible and no later than 72 hours, and we also notify the persons affected.

9. How long we keep your data

Your examination and treatment records are kept for the periods prescribed by healthcare legislation. Invoices and accounting records are kept for the periods set out in tax legislation. Information relating to enquiries that did not lead to treatment is kept for a maximum of two years from the last contact. Data whose retention period has expired is deleted, destroyed or anonymised.

10. Cookies

Our websites use cookies that are strictly necessary for the site to function, as well as analytics and marketing cookies for visit statistics and advertising measurement. Non-essential cookies do not run until you give your consent. You can set your preference in the cookie banner that appears on your first visit to our site, and later change or withdraw that preference through the same banner. You can also delete or block cookies in your browser settings.

11. Your rights

Under Article 11 of the KVKK, you have the right to: learn whether your personal data is processed; request information if it has been processed; learn the purpose of the processing and whether the data is used in line with that purpose; know the third parties in Türkiye or abroad to whom it has been transferred; request rectification if it has been processed incompletely or inaccurately; request its erasure or destruction; request that these actions be notified to the third parties to whom it has been transferred; object to an outcome against you resulting from analysis exclusively by automated systems; and claim compensation for any damage you suffer as a result of unlawful processing.

Our patients living in the European Economic Area may also exercise, under the GDPR, the rights of access, rectification, erasure, restriction of processing, data portability and objection; withdraw the explicit consent they have given at any time; and lodge a complaint with the data protection authority in their country of residence.

12. Applications

To exercise your rights, you may send your request in writing to our address given in Section 1, or send it from the e-mail address registered in our system to info@avrupacerrahi.net. It is sufficient to state clearly your first name, surname, contact details and your request. International patients may submit their applications in their own language or in English. We will conclude your application free of charge within 30 days at the latest. If the action requires an additional cost, a fee may be charged in accordance with the tariff set by the Personal Data Protection Board (KVKK Board).

13. Changes

We may update this notice in line with changes in legislation or in our services. The current version is always published on this page. The date at the top of the page shows the date of the last update.