Protection of Personal Data

About this translationThis is an English translation of the Turkish policy, provided for information. The practice is based in Turkey and is governed by Turkish Law No. 6698 on the Protection of Personal Data; in case of any discrepancy, the Turkish version prevails.

Under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), the following explains how your personal data is processed in the course of online psychological services.

Important — health data All data processed in the course of psychological work is treated, under Article 6 of the KVKK, as special-category personal data (health data), and is subject to a stricter protection regime than ordinary personal data.

Contents

  1. Data controller
  2. Scope of the service (online)
  3. Data processed
  4. Purposes of processing
  5. Legal grounds
  6. Transfers to third parties
  7. Retention periods
  8. Security measures
  9. Children and young people
  10. Data breach notification
  11. Your rights (KVKK Art. 11)
  12. How to apply

1. Data controller

Haktan Tay — Psychologist, psychoanalytic orientation
Email: psikologhaktantay@gmail.com
Form of service: online (remote) sessions only

As regards professional ethics, the Ethics Regulation of the Turkish Psychological Association (TPD) and the ethical framework of psychoanalytic training institutions (ECF, NEL) apply.

2. Scope of the service (online sessions)

The service is offered remotely only (video or voice calls). No face-to-face clinical meetings take place. Therefore:

3. Personal data processed

CategoryDataSource
IdentityFirst and last nameContact form / email
ContactEmail, phoneProvided by the client
ContentSession request, subject, preferred date, messageContact form
Health (special category)Psychological content shared during sessions, clinical notesClient’s own statements
FinancialPayment receipts / invoice detailsBank transfer / payment method

4. Purposes of processing

5. Legal grounds

Your data is processed on the following legal grounds:

6. Transfers to third parties

Given the nature of the service, the following data processors are used:

Online session platform

Sessions take place on communication platforms that are end-to-end encrypted or offer equivalent security. These platforms act as third-party data processors. Some of their servers may be located abroad (EU / USA); transfers abroad under Article 9 of the KVKK therefore arise.

Contact form infrastructure

The contact form on this site runs on Google Forms. Data sent through the form is transferred to the servers of Google LLC. (Google Privacy Policy)

Other

Beyond these, the data you send us through the contact form and in sessions is not shared with third parties, not sold and not used for advertising. For the Google Ads measurement tag on the site, see the Privacy & Cookies page.

7. Retention periods

Type of dataPeriodBasis
Contact form (not followed by sessions)1 yearReasonable period to answer the person’s request
Clinical records (minimal notes)10 yearsTPD recommendation and limitation periods
Invoicing / accounting5 years (minimum)Tax Procedure Law
Email correspondence2 yearsContinuity of communication

At the end of these periods, records are deleted, destroyed or anonymised.

8. Security measures (KVKK Art. 12)

Technical measures:

Administrative measures:

9. Children and young people

Sessions with people under 18 take place only with the written consent of a parent or guardian. The consent form refers explicitly to this policy. The balance between confidentiality and the duty to inform parents is managed within the framework of the TPD Ethics Regulation.

10. Data breach notification

If a data breach is detected:

11. Your rights (KVKK Art. 11)

As a data subject, you have the right to:

12. How to apply

To exercise your rights you may apply in writing to psikologhaktantay@gmail.com, in accordance with the Communiqué on the Procedures and Principles of Applications to the Data Controller. Applications are answered free of charge within 30 days at the latest.

Your application should state your full name, identity number (for Turkish citizens) or another identifying document, address, the subject of your request and, where necessary, supporting documents.

Legal notice This text is for information purposes. In specific situations the relevant legislation applies, in particular the KVKK, the Turkish Regulation on Personal Health Data and the TPD Ethics Regulation. Please follow updates to the legislation.