Legal

Privacy Notice

About this translationThis is an English translation of the Turkish notice (Aydınlatma Metni), provided for information. In case of any discrepancy, the Turkish version prevails.

In accordance with Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, we, as data controller, inform you as follows.

1. Identity of the data controller

Haktan Tay — Psychologist, psychoanalytic orientation
Email: psikologhaktantay@gmail.com
Website: haktantay.com
Form of activity: online psychological services only

2. Purposes for which your personal data is processed

The data you send us is processed for the following purposes:

• replying to your request for contact;
• scheduling and conducting online sessions;
• concluding and performing the contractual relationship;
• meeting clinical record-keeping obligations within the framework of professional ethics (TPD Ethics Regulation);
• meeting legal obligations (tax, invoicing, accounting);
• use as evidence in possible legal disputes.

3. Parties to whom personal data may be transferred

Your data may be transferred to the following third parties:

• Online session platform providers: to keep sessions running technically (as a rule, an end-to-end encrypted channel is used). These services may use servers abroad (assessed under Article 9 of the KVKK).
• Contact form provider (Google LLC — Google Forms): data sent through the form is transferred to Google’s servers.
• Email service provider (Google LLC — Gmail): for email correspondence with you.
• Accountant: limited data sharing to meet legal obligations.
• Banks / payment institutions: to collect session fees.
• Competent public authorities: only upon a legal request or court order.

4. Method of collection and legal grounds

Your personal data is collected by the following electronic means:

• the contact form on the website (first and last name, email, phone number, subject, preferred date and message);
• email correspondence;
• your own statements during online sessions;
• bank or payment data in the course of payment.

Legal grounds:

• KVKK Art. 5/2-c — necessity for the conclusion and performance of a contract
• KVKK Art. 5/2-ç — compliance with legal obligations
• KVKK Art. 5/2-f — legitimate interest of the data controller (only insofar as it does not harm fundamental rights and freedoms)
• KVKK Art. 6/3 — for health data: processing by a person under a duty of confidentiality for the purpose of providing health services
• your explicit consent for processing beyond the above (KVKK Arts. 5/1 and 6/2)

5. Cases requiring explicit consent

Your explicit consent is sought separately in the following cases:

• recording the image or sound of a session (default: no recording);
• sharing clinical content in supervision (other than in anonymised form);
• processing personal data that is not necessary to provide the service;
• commercial communications (newsletters and the like), if requested.

6. Your rights as a data subject (KVKK Art. 11)

You have the following rights over your personal data:

1. to learn whether your personal data is processed;
2. to request information about it if it has been processed;
3. to learn the purpose of processing and whether it is used in line with that purpose;
4. to know the third parties in Turkey or abroad to whom it has been transferred;
5. to request correction if it is incomplete or inaccurate;
6. to request deletion or destruction under the conditions set out in Article 7 of the KVKK;
7. to request that third parties to whom the data was transferred be notified of any correction, deletion or destruction;
8. to object to an outcome against you resulting from analysis by automated systems;
9. to claim compensation if you suffer damage because of unlawful processing.

7. How to apply

To exercise your rights you may apply as follows, in accordance with the Communiqué on the Procedures and Principles of Applications to the Data Controller:

• Email: psikologhaktantay@gmail.com

Your application should include your full name, identity number (for Turkish citizens) or another identifying document, address and the subject of your request, together with any supporting documents. Applications are free of charge and are concluded within 30 days at the latest.

If you are not satisfied with the reply to your application, you retain the right to lodge a complaint with the Turkish Personal Data Protection Board within 30 days.