PRIVACY POLICY AND TERMS OF USE (KVKK)
1. PURPOSE AND SCOPE
Dr. Ahmet Demir, operating at the address Merkez Mahallesi Palazoğlu Sokak Eren Palas Apt. No:5-7 Daire:9 (hereinafter referred to as "Physician/Clinic/Employer"), places great importance on the protection of personal data of all individuals with whom we come into contact while carrying out our activities, in compliance with the Personal Data Protection Law No. 6698 and the European Union General Data Protection Regulation (GDPR), which regulate this as a constitutional right.
This Personal Data Protection Policy has been prepared to inform you about the processes related to the collection, use, sharing, and storage of personal data by Dr. Ahmet Demir, operating at the address Merkez Mahallesi Palazoğlu Sokak Eren Palas Apt. No:5-7 Daire:9.
In the process of processing and protecting personal data, the relevant legal regulations in force shall be primarily applied. In this context, the main purpose of this Personal Data Protection and Processing Policy (“Policy”) is to set forth the rules, measures, duties, and responsibilities adopted by the Physician and Clinic within the framework of personal data protection legislation in a methodological approach and to ensure transparency in the measures we implement for the protection of personal data.
2. DEFINITIONS AND ABBREVIATIONS
The terms used in the implementation of this Policy have the following meanings:
Employees: Refers to the employees of the Physician and Clinic.
Contact Person: The individual responsible for monitoring personal data processing activities within the Physician and Clinic and ensuring the implementation of KVKK Policies and Procedures on an individual basis.
Personal Data: Any information related to an identified or identifiable natural person. For example, name, surname, address, phone number, date of birth, place of birth, eye color, Turkish Republic identification number.
Personal Data Owner: The natural person whose personal data is processed. For example, an employee, visitor, customer, or interested person.
Processing of Personal Data: Any operation performed on personal data, whether fully or partially automated or by non-automated means, provided that it is part of a data recording system. For example, obtaining, recording, storing, modifying, transferring.
KVK Law: Refers to the Personal Data Protection Law No. 6698.
GDPR: General Data Protection Regulation of the European Union.
3. PRINCIPLES OF PERSONAL DATA PROCESSING
The Physician and Clinic process personal data in accordance with the procedures and principles stipulated by the KVKK and other relevant laws.
The following principles are adhered to in the processing of personal data:
a) Compliance with the Law and Principles of Fairness:
The Physician and Clinic process personal data in compliance with legal regulations, the law, and principles of fairness.
Personal data owners are informed accordingly.
b) Accuracy and Up-to-Date When Necessary:
The Physician and Clinic take necessary measures to ensure that the personal data they process are accurate and up-to-date.
c) Processing for Specific, Explicit, and Legitimate Purposes:
The Physician and Clinic clearly and explicitly determine the legitimate and lawful purposes for processing personal data.
Personal data are processed only as necessary and in connection with the services provided.
ç) Relevance, Limitation, and Proportionality to the Purpose for Which They Are Processed:
The Physician and Clinic process personal data only for the purposes defined within the scope of the provided services.
They avoid collecting, processing, or storing personal data that is not necessary for achieving the intended purpose.
d) Retention for the Period Prescribed by Relevant Legislation or Necessary for Processing Purposes:
The Physician and Clinic store personal data in compliance with the provisions of legal regulations.
Upon the expiration of the retention period, personal data are deleted, anonymized, or destroyed.
CONDITIONS FOR PROCESSING PERSONAL DATA:
The Physician and Clinic process personal data in accordance with the provisions of the Personal Data Protection Law No. 6698 (KVKK) by adhering to the following conditions:
Personal data cannot be processed without the explicit consent of the relevant person.
Personal data can only be processed with the explicit consent of the data owner/relevant person. In this regard, patients are informed about the matter, and their explicit consent is obtained based on their free will.
(2) In the presence of one of the following conditions, personal data may be processed without the explicit consent of the relevant person:
a) Explicitly stipulated by law.
b) If it is necessary to protect the life or physical integrity of the person who is unable to express their consent due to actual impossibility or whose consent is not legally valid.
c) If the processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
ç) If it is necessary for the data controller to fulfill its legal obligations.
d) If the relevant person has made their personal data public.
e) If processing is mandatory for the establishment, exercise, or protection of a legal right.
f) If data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.
CONDITIONS FOR PROCESSING SPECIAL CATEGORY PERSONAL DATA
The Physician and Clinic comply with the regulations specified in the Personal Data Protection Law No. 6698 (KVKK) regarding the processing of special category personal data. KVKK Article 6(1) defines special category personal data as information related to an individual’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire, association, foundation, or union membership, health, sexual life, criminal convictions, security measures, as well as biometric and genetic data.
The Physician and Clinic process special category personal data under the following conditions:
It is processed with the explicit consent of the relevant individual.
Personal data, excluding health and sexual life data, may be processed without the explicit consent of the individual in cases stipulated by law.
Personal data related to health and sexual life may be processed without explicit consent for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment, and healthcare services, as well as for planning and managing healthcare services and financing. In such cases, processing is carried out by persons or authorized institutions and organizations that are under a legal obligation to maintain confidentiality.
COLLECTING AND PROCESSING PERSONAL DATA
In accordance with Articles 4, 5, and 6 of the Personal Data Protection Law (KVKK) and Articles 5, 7, 9, and 10 of the Regulation, personal data is processed based on the Personal Data Processing Inventory, which is required to include the following information:
Data category
Purposes and legal basis for processing personal data
Recipient/recipient groups to whom data is transferred
Data subject groups
Maximum retention period necessary for the purposes of processing personal data
Transfer to foreign countries
Administrative and technical measures taken for data security
THIRD PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED AND PURPOSES OF TRANSFER
The Physician and Clinic strictly adhere to the conditions stipulated in the KVKK regarding the sharing of personal data with third parties while preserving the provisions stated in other applicable laws.
In this context, personal data is not transferred to third parties without the explicit consent of the data owner. However, in the presence of any of the following conditions regulated under KVKK, personal data may be transferred by the Physician and Clinic without obtaining the explicit consent of the data owner:
Explicitly stipulated by law.
If it is necessary to protect the life or physical integrity of a person who is unable to express their consent due to actual impossibility or whose consent is not legally valid.
If the processing of personal data belonging to the parties of a contract is necessary for the establishment or performance of the contract.
If it is necessary for the data controller to fulfill its legal obligations.
If the relevant person has made their personal data public.
If processing is mandatory for the establishment, exercise, or protection of a legal right.
If data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data owner.
With adequate measures taken, special category personal data excluding health and sexual life may be transferred if stipulated by law. However, special category personal data related to health and sexual life may be transferred without obtaining explicit consent for the following purposes:
Protection of public health.
Preventive medicine.
Medical diagnosis.
Execution of treatment and healthcare services.
Planning and management of healthcare services and financing.
In the transfer of special category personal data, the conditions specified for processing such data are strictly followed.
Situations Where Data May Be Processed Without Explicit Consent Under GDPR:
According to GDPR Article 9/2/h, Article 6/1/b, and Article 6/1/f, the following conditions allow the processing of personal data without explicit consent:
For the purpose of conducting medical examinations, diagnosis, treatment, and healthcare services, your health data, classified as Special Category Personal Data, may be processed by the Clinic without your explicit consent, as required by law.
To conduct follow-up checks after medical diagnosis and treatment, communicate with you directly, and manage appointment processes, your personal data may be processed by the Clinic without your explicit consent.
For the management of patient satisfaction and request handling, your personal data may be processed by the Clinic without your explicit consent.
According to GDPR Article 6/1/c, your personal data may be processed without obtaining explicit consent in the following cases, based on legal obligations:
Creation of patient records.
Retention of required health-related data as per legal regulations.
Verification of payment transactions and issuance of invoices.
Fulfillment of tax obligations.
Compliance with obligations under the Ministry of Health regulations.
Fulfillment of obligations under Health Tourism Regulations.
Ensuring data security.
Compliance with legal obligations before judicial authorities.
Fulfillment of administrative obligations before government institutions and organizations.
STORAGE OF PERSONAL DATA UNDER RELEVANT LEGISLATION
The Physician and Clinic securely store personal data in physical or electronic environments in compliance with KVKK and other relevant legal provisions, ensuring that the company's operations are carried out properly.
Initially, the retention period for personal data is examined, and compliance with this period is ensured.
If no legal retention period is specified, a necessary storage period is determined, and personal data is retained accordingly.
Once the retention period expires, personal data is deleted, destroyed, or anonymized.
However, in cases where the data controller has a legitimate interest, personal data may be retained until the expiration of the general statute of limitations (ten years) stipulated in the Code of Obligations, provided that it does not harm the fundamental rights and freedoms of data owners, even after the processing purpose and the legally defined periods have expired.
In this context, the Physician and Clinic provide necessary training to the relevant units within the organization to ensure awareness and compliance with data protection regulations.
MEASURES TAKEN FOR DATA SECURITY
The Physician and Clinic take all necessary technical and administrative measures to ensure an adequate level of security for the protection of personal data.
According to Article 12(1) of KVKK, the following measures are implemented:
Preventing the unlawful processing of personal data.
Preventing unlawful access to personal data.
Ensuring the secure storage of personal data.
The measures taken by the Physician and Clinic in this context are listed below:
Administrative Measures
The Physician and Clinic conduct necessary audits to ensure compliance with the legal provisions.
If personal data is illegally obtained by unauthorized parties, the Physician and Clinic notify the affected individual and the relevant authority as soon as possible.
In the sharing of personal data, security is ensured by framework agreements, consent forms, explicit consent declarations of data owners, or contractual provisions with the recipients of the data.
Qualified and experienced personnel are employed for personal data processing, and necessary KVK training is provided to employees.
Technical Measures
The Physician and Clinic employ knowledgeable and experienced personnel to ensure data security and provide necessary KVK training.
Internal controls are conducted regularly within the established systems.
A technical infrastructure is established to prevent and/or monitor unauthorized leaks of personal data outside the institution, ensuring the implementation of necessary security matrices.
RIGHTS OF PERSONAL DATA OWNERS UNDER ARTICLE 11 OF KVKK
Under Article 11 of the Personal Data Protection Law No. 6698 (KVKK), personal data owners can apply to the Physician and Clinic at the provided address to exercise the following rights:
a) Learn whether their personal data is being processed.
b) Request information about their personal data if it has been processed.
c) Learn the purpose of processing personal data and whether it is being used in accordance with that purpose.
ç) Know the third parties, both domestic and international, to whom their personal data has been transferred.
d) Request correction of personal data if it is incomplete or incorrect.
e) Request the deletion or destruction of personal data in accordance with KVKK and other relevant legal provisions.
f) Request that corrections, deletions, or destructions of personal data be notified to third parties to whom the personal data has been transferred.
g) Object to any unfavorable outcomes arising from the processing of personal data solely through automated systems.
ğ) Request compensation for any damages incurred due to the unlawful processing of personal data.
RIGHTS OF DATA SUBJECTS UNDER GDPR
As a Data Subject, your personal data is also protected under GDPR. In cases falling under the jurisdiction of GDPR (for EU citizens or residents of EU countries), the rights of data subjects are as follows:
Right of Access (GDPR Article 15):
The data subject has the right to confirm whether personal data concerning them is being processed by the Clinic, and, if so, to learn the details mentioned in GDPR Article 15.
Right to Rectification (GDPR Article 16):
The data subject has the right to request the correction of any inaccurate personal data held by the Clinic.
Right to Erasure (GDPR Article 17):
The data subject has the right to request the deletion of personal data stored by the Clinic. If the conditions mentioned in GDPR Article 17 are met, the Clinic will delete the personal data without delay.
Right to Restriction of Processing (GDPR Article 18):
If the data subject disputes the accuracy of their personal data, they have the right to request that the use of their data be restricted until its accuracy is confirmed.
If the processing of personal data is unlawful and the data subject requests the deletion of the data, they have the right to request the restriction of data usage until the request is fulfilled.
If the Clinic no longer requires personal data for its processing purposes, the data subject has the right to request the restriction of data usage.
According to GDPR Article 21(1), if the data subject objects to the processing activity, they have the right to request that the processing be restricted until it is verified whether the legitimate grounds for processing by the Clinic outweigh the legitimate grounds of the data subject.
Right to Data Portability (GDPR Article 20):
The data subject has the right to request that their personal data held by the Clinic be transferred to another data controller, provided it is technically feasible. However, this right may only be exercised when data processing is based on consent or is necessary for the performance of a contract.
Right to Object (GDPR Article 21):
The data subject has the right to object to the processing of their personal data, including for direct marketing purposes.
We continue our operations with the awareness that personal data security is of paramount importance in all the products and treatments we offer.
"Clarification Text"
In accordance with the provisions of Personal Data Protection Law No. 6698 ("KVKK") and the General Data Protection Regulation (GDPR), Dr. Ahmet Demir and the Clinic, located at Merkez Mahallesi Palazoğlu Sokak Eren Palas Apt. No:5-7 Kat:2 Daire:9 Şişli/İstanbul (hereinafter referred to as "Physician/Clinic/Employer"), as the Data Controller, inform you that your personal information will be recorded, stored, updated, disclosed to third parties when permitted by law, transferred, classified, and processed in the forms specified in KVKK and GDPR within the scope of the legal regulations. We are providing this information regarding our mutual rights and obligations under these legal frameworks.
In accordance with the relevant legislation, we will record and store your personal information in our archives in order to establish the Physician-Patient relationship and provide you with healthcare services (diagnosis, treatment, care services, etc.) in line with the benefit of the patient and public health. Specifically:
In compliance with the Private Hospitals Law, Private Hospitals Regulation, Health Application Communique, Patient Rights Regulation, and other related regulations, we are required to collect and store the necessary patient information, including identity, address, phone number, medical history, and other necessary details for identification, either in electronic or paper format, as part of the medical patient file and documentation.
For public health and preventive healthcare services, we inform you that your personal data will be shared with the Ministry of Health, Provincial Health Directorates, Public Health Centers, and other related units of the Ministry of Health, as well as with the Social Security Institution and your private health insurance provider when applicable. Personal data may also be shared with authorized authorities and persons, as required by e-health systems like e-Nabız or as part of notification and/or reporting obligations imposed on us.
PURPOSES, METHODS OF COLLECTION AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Your personal data will be processed for the purposes of establishing the Physician-Patient relationship, fulfilling the terms of the contract, and using the information in the services we can provide to you. This includes collecting necessary details such as identity, address, tax number, and personal health data for identifying the person who is performing the action. These details will be recorded in electronic (internet/mobile, etc.) or paper formats, and all related documents and records will be organized. We will comply with information storage, reporting, and notification obligations imposed by legislation, competent authorities, and other organizations. Your personal data will also be processed to improve service activities and quality, provide requested and other products/services, and for the processing of special category personal data due to communication, information provision, and similar processes within the contractual relationship.
Your blood type, laboratory and imaging results, tests, allergies, chronic diseases, sexually transmitted diseases, infectious diseases, previous surgeries/operations, e-nabız information, medications you regularly use, Covid-19-related information, medical treatments, prescription information, harmful habits, body analysis, and death information, as well as other health data and personal information required for the treatment and applications to be performed, will be processed for the following purposes: to create a patient file, conduct preventive medicine, examination, medical diagnosis, treatment and care services, manage follow-up after medical diagnoses and treatments, manage complications that may arise, communicate with you directly, manage appointment processes, conduct patient satisfaction and request management, fulfill legal and contractual obligations, retain health data in accordance with the relevant legislation for the required period, obtain consultations from other relevant specialists if necessary, fulfill obligations under health tourism regulations, plan transfer, accommodation, and interpreter services for health tourism, promote medical treatments and applications, inform third parties about medical procedures, plan and manage healthcare services and financing, ensure workplace safety, fulfill responsibilities arising from the legal relationship between doctor and patient, and meet financial, administrative, and technical security obligations, and fulfill public duties.
The personal data and special category personal data listed above will be processed in accordance with the purposes stated above and the relevant legislation to carry out medical treatments, diagnosis, preventive healthcare, and similar procedures. If you do not provide the relevant personal data, the legal obligations imposed on the Physician and Clinic will not be fulfilled, and your treatment and/or recovery processes cannot be conducted successfully.
Other processing activities for your personal data may include HR operations, internal clinic operations, legal, technical, and administrative activities, strategy planning, partner/supplier management, customer satisfaction, corporate communication activities, event planning and execution, internal training programs, workplace safety, occupational health and safety services, technical service, debt collection, customer/product promotion, personalized advertising, surveys, statistical analysis, improvement of service quality, billing, external services, technology services, complaint responses, data security measures, financial reconciliation, legal compliance with regulatory requests, and legal, administrative, and technical support for fulfilling obligations.
Your personal data will be processed as part of the healthcare services provided to you, including:
Consultation, treatment, medical reports, lab results, imaging results, test data, health reports, and personal health declarations provided by you;
Completion of the "Patient Information and Consent Form" required by the Physician and Clinic for the treatment to be provided;
Communication via the clinic’s corporate website, email, or phone;
Photography/video recordings taken before, during, or after medical procedures;
Remote diagnostic and follow-up consultations via online platforms (e.g., WhatsApp, Zoom, Skype, Messenger, Google, Instagram, Facebook, etc.) and messages or audio/video calls sent through these platforms.
Your personal and special category personal data may be shared with:
Consulting specialists, insured employees, suppliers, financial and tax advisors, legal consultants, IT providers, database providers, software and web service providers, translators, data protection officers, tourism agencies, regulatory and law enforcement authorities, and public authorities as required by law or as part of legal obligations.
Your data will only be shared with authorized entities in secure environments and will not be disclosed to third parties without your consent or unless legally required. Personal data will be processed in accordance with the KVKK, GDPR, and relevant legislation, ensuring compliance with data protection principles.
STORAGE OF PERSONAL DATA
The method of collecting personal data includes collecting your data through various digital channels such as questions, messages sent to our website, and phone calls, either verbally, in writing, or electronically.
The personal data we collect is securely stored in either physical or electronic environments for a reasonable period of time in order to carry out the activities of the Physician and Clinic. In these activities, the Physician and Clinic ensure compliance with all obligations set forth in the relevant legislation, including the KVKK, for the protection of personal data.
In accordance with the relevant regulations, except in cases where personal data is required or permitted to be retained for longer periods, when the purposes of processing the personal data cease, the Physician and Clinic will delete, destroy, or anonymize the data either automatically or upon the request of the data owner, using different available techniques. When personal data is deleted through these methods, it will be permanently destroyed and cannot be used or restored.
In cases where the data controller has a legitimate interest and the law permits it, personal data may be stored even after the purpose of processing and the time periods specified in the relevant laws have expired, provided that the fundamental rights and freedoms of the data owners are not harmed. After the expiration of the statute of limitations, personal data will be deleted, destroyed, or anonymized according to the procedure mentioned above.
MEASURES TAKEN FOR DATA SECURITY
The Clinic takes all necessary technical and administrative measures to ensure an appropriate level of security for the protection of personal data. The measures outlined in Article 12(1) of KVKK are as follows:
Preventing the unlawful processing of personal data,
Preventing unlawful access to personal data,
Ensuring the secure storage of personal data.
PROCESSING OF IMAGE RECORDS
For the purpose of ensuring the overall and service security of the premises and operations where the Clinic is located, image recordings of visitors, employees, and other relevant individuals are made in accordance with the basic principles set forth in KVKK.
PROCESSING OF PERSONAL DATA OF BUSINESS PARTNERS
The Clinic may process personal data of employees of business partners such as medical laboratories, product suppliers, and other partners, as part of fulfilling the operations and activities carried out with these partners. This is done when necessary for fulfilling the obligations of the work or for purposes specified by law, to ensure the smooth operation of services, to implement human resources goals and policies, and to ensure the legal and commercial security of mutual collaboration.
APPLICATION PROCEDURE AND RIGHTS
Under Article 11 of KVKK, your rights are as follows; by applying to us, you have the right to:
a) Learn whether your personal data is processed,
b) Request information about the data if it has been processed,
c) Learn the purpose of processing and whether it is used in accordance with that purpose,
ç) Know the third parties to whom your personal data has been transferred, both within the country and abroad,
d) Request correction if the data has been processed incompletely or inaccurately,
e) Request the deletion or destruction of your personal data as outlined in Article 7 of KVKK,
f) Request notification of the actions taken in accordance with (d) and (e) to third parties to whom the data has been transferred,
g) Object to the outcome resulting from the exclusive analysis of your personal data through automated systems,
ğ) Request the rectification of damages if you are harmed due to unlawful processing of personal data by the Clinic.
Your requests in the application will be concluded free of charge within thirty days at the latest, depending on the nature of the request. However, if the process requires additional costs for the Clinic, a fee may be charged according to the tariff determined by the Personal Data Protection Board in the Regulation on Application Procedures and Principles. According to Article 13 of KVKK, Data Subject Rights can be exercised by following the methods and procedures specified in the “Regulation on Application Procedures and Principles”, published on March 10, 2018, in the Official Gazette No. 30356.
Exceptions to the Right of Application
According to Article 28 of KVKK, data subjects cannot assert their rights in the following cases:
Personal data processed for purposes of research, planning, and statistics, by anonymizing them for official statistics,
Processing personal data for artistic, historical, literary, or scientific purposes, or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, privacy, or personality rights,
Processing personal data in preventive, protective, and intelligence activities conducted by public institutions and organizations authorized by law for national defense, national security, public security, public order, and economic security,
Processing personal data by judicial authorities or enforcement agencies regarding investigation, prosecution, trial, or execution procedures.
According to Article 28/2 of KVKK, the provisions regarding the data controller's obligation to inform in Article 10, the right to request rectification of damages, and the obligation to be registered in the Data Controllers Registry in Article 16 do not apply in the following situations, in accordance with the objectives and fundamental principles of the law and in a proportionate manner:
When personal data processing is necessary for the prevention of crime or for a criminal investigation,
When personal data has been made public by the data subject,
When personal data processing is required by public institutions and organizations or professional organizations with public duties authorized by law to carry out regulatory or oversight duties, or for necessary disciplinary inquiries or prosecutions,
When personal data processing is necessary for protecting the state's economic and financial interests in matters related to budget, taxes, and finance.
RIGHTS OF DATA SUBJECTS UNDER GDPR
As a Data Subject, your personal data is also protected under GDPR. In cases falling under the jurisdiction of GDPR (for EU citizens or those residing in EU countries), the rights of data subjects are as follows:
Right of Access (GDPR Article 15):
The data subject has the right to confirm whether their personal data is processed by the Clinic, and if processed, to learn the details mentioned in GDPR Article 15.
Right to Rectification (GDPR Article 16):
The data subject has the right to request correction of any inaccurate personal data held by the Clinic.
Right to Erasure (GDPR Article 17):
The data subject has the right to request the deletion of their personal data held by the Clinic. If the conditions outlined in GDPR Article 17 occur, the Clinic will delete personal data without delay.
Right to Restriction of Processing (GDPR Article 18):
The data subject has the right to request the restriction of the use of their personal data until the accuracy of the data is confirmed by the Clinic if they object to the accuracy of the data.
If the data subject requests the deletion of their personal data due to unlawful processing, they have the right to request the restriction of data usage until the request is fulfilled.
The data subject has the right to request the restriction of the use of their personal data when the Clinic no longer needs the data for the processing purpose.
Under GDPR Article 21(1), if the data subject objects to the processing activity, they have the right to request the restriction of data usage until it is verified whether the legitimate grounds for processing by the Clinic outweigh the legitimate grounds of the data subject.
Right to Data Portability (GDPR Article 20):
The data subject has the right to request that their personal data, held by the Clinic, be transferred to another data controller, provided it is technically feasible. This right can only be used when data processing is based on consent or is necessary for the performance of a contract.
Right to Object (GDPR Article 21):
The data subject has the right to object to the processing of their personal data, based on specific reasons related to their situation, under GDPR Articles 6/1(e) and (f).
We continue our activities with the awareness that personal data security is of utmost importance in all the products and treatments we offer.
CONSENT AND APPROVAL
By reading and accepting this Clarification Text, you acknowledge that you are fully and completely informed about the data processing activities carried out by the Physician and Clinic, that you have learned your rights as outlined by KVKK and GDPR, and that you give your free and voluntary consent to the Physician and Clinic for the processing of your Personal Data and Special Category Personal Data as specified in this Clarification Text. You hereby acknowledge, declare, and commit to this consent.