Privacy Policy

Introduction:

Welcome to the Avangart Clinic Turkey Limited website privacy policy.

Avangart Clinic Turkey Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website, make an enquiry through our website, submit information so that it can be passed to a licensed Turkish clinic for dental treatment assessment, request provisional treatment-related information or a quotation, proceed with a booking, or continue communicating with us following a website enquiry. It also tells you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Avangart Clinic Turkey Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you make an enquiry, request information, submit photographs, X-rays, scans or other dental information, request provisional treatment-related information or a quotation, or proceed with a booking.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy, clinic privacy notice, consent form, fair processing notice or cookie policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why your data is being used. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

This website is operated by Avangart Clinic Turkey Limited.

Avangart Clinic Turkey Limited is a company registered in England and Wales under company number 09728638. It provides a UK-based information, referral, communication and booking service. Avangart Clinic Turkey Limited does not provide dental treatment, does not operate as a healthcare facility and is not the treating clinic.

Avangart Clinic Turkey is the Turkish facilitator and stakeholder entity involved in non-clinical patient coordination, clinic liaison and treatment-related arrangements in Türkiye. Avangart Clinic Turkey is not the treating clinic and does not provide dental treatment.

Dental treatment is provided only by licensed Turkish dental clinics. Those clinics are separate legal and clinical providers and are responsible for the dental assessment, treatment planning, informed consent, treatment, clinical records, aftercare and clinical decisions they provide.

Avangart Clinic Turkey Limited is responsible for the operation of this website and for personal data collected through the website, including enquiry forms and related website communications.

Where your enquiry progresses to clinical assessment, treatment planning, treatment, aftercare or complaint handling, relevant personal data may be shared with Avangart Clinic Turkey and/or with the licensed Turkish dental clinic involved in reviewing, planning or providing your treatment. The clinical assessment, treatment planning, treatment, clinical consent, clinical records and clinical aftercare are provided by the licensed Turkish clinic, not by Avangart Clinic Turkey Limited or Avangart Clinic Turkey. Those parties may act as separate data controllers for the personal data they process for their own legal, clinical, regulatory or operational purposes.

For the purposes of this privacy policy, “Avangart Clinic Turkey”, “we”, “us” or “our” means Avangart Clinic Turkey Limited in relation to the operation of this website and website enquiry handling, unless the context refers to data shared with Avangart Clinic Turkey or a licensed Turkish dental clinic for treatment-related purposes.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Avangart Clinic Turkey

Email address: contact@avangartclinic.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). Where your personal data is processed in Türkiye by Avangart Clinic Turkey or by a licensed Turkish dental clinic, you may also have the right to make a complaint to the Turkish Personal Data Protection Authority (www.kvkk.gov.tr).

We would, however, appreciate the chance to deal with your concerns before you approach a regulator, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, date of birth, age, gender, nationality, passport details and similar identifiers where needed for enquiry, booking or treatment-related purposes.
Contact Data includes address, email address, telephone numbers, WhatsApp or other messaging details, and emergency contact details where provided.
Financial Data includes bank account details, payment card details, payment references and other payment or refund information.
Transaction Data includes details about quotations, payments to and from you, invoices, receipts, bookings, refunds and other details of services requested or arranged through us.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and other technology on the devices you use to access this website.
Enquiry and Assessment Data includes information you provide when making an enquiry, requesting provisional treatment-related information or a quotation, submitting dental photographs, smile photographs, videos, X-rays, scans or other documents, and communicating with us by website form, email, telephone, WhatsApp, social media or other messaging channels.
Usage Data includes information about how you use our website and online services.
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties, your communication preferences, feedback, reviews, testimonials and survey responses.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect Special Categories of Personal Data about you, including dental and health information. This may include dental photographs, X-rays, CBCT scans, medical history, dental history, medication information, allergies, pregnancy information, treatment suitability information, proposed treatment-related information supplied by a licensed Turkish clinic, clinical notes where shared with us for referral, booking, facilitation, aftercare communication or complaint-handling purposes, consent-related information, aftercare information and complaint records.

Dental and health information is sensitive personal data. It may be shared with Avangart Clinic Turkey and/or the licensed Turkish clinic involved in reviewing, planning or providing your treatment where this is necessary for treatment assessment, treatment planning by the licensed Turkish clinic, booking coordination, treatment-related arrangements, aftercare communication, complaint handling, legal record-keeping or regulatory compliance.

If you fail to provide personal data

Where we need to collect personal data by law, under the terms of a contract, or in order to assess whether treatment may be suitable, and you fail to provide that data when requested, we may not be able to respond to your enquiry, obtain or communicate provisional treatment-related information or a quotation supplied by a licensed Turkish clinic, arrange a booking, provide treatment-related coordination or continue with aftercare communications. We will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Contact, Financial, Enquiry and Assessment Data by filling in forms or by corresponding with us by post, phone, email, WhatsApp, social media or otherwise. This includes personal data you provide when you:

make an enquiry through our website;
request information, a consultation, provisional treatment-related information or a quotation supplied by a licensed Turkish clinic;
submit photographs, X-rays, scans, medical information, dental information or other documents for assessment;
proceed with a booking, make payment, request aftercare, give feedback or raise a complaint; or
request marketing to be sent to you or otherwise contact us.

Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the UK;

(b) advertising networks based inside or outside the UK; and

Contact, Financial and Transaction Data from providers of technical, payment, booking, communication, accommodation or transfer services based inside or outside the UK.

Identity, Contact, Enquiry and Assessment Data from Avangart Clinic Turkey, licensed Turkish dental clinics, referral partners, business partners, healthcare professionals, laboratories, social media platforms, review platforms or other persons involved in your enquiry, assessment, booking, treatment-related arrangements or aftercare.

Identity and Contact Data from publicly available sources based inside or outside the UK.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where it is necessary for medical or dental assessment, treatment planning or healthcare services provided by a licensed Turkish clinic, clinical record keeping, patient safety, legal claims, or the establishment, exercise or defence of legal rights.
Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Where Turkish Personal Data Protection Law No. 6698, known as the PDPL or KVKK, applies, we will process personal data only where a lawful basis applies. This may include explicit consent where required, processing necessary for the performance of a contract, processing necessary for compliance with legal obligations, processing necessary for the establishment, exercise or protection of a right, processing necessary for legitimate interests where permitted, and processing permitted under Turkish law for medical diagnosis, treatment, care services, healthcare planning and management.

Generally, we do not rely on consent as the only legal basis for processing your personal data, although we will get your consent where consent is required, including before sending third party direct marketing communications to you by email or text message and before publishing patient photographs, videos, testimonials or similar marketing material. You have the right to withdraw consent at any time by contacting us.

Purposes for which we will use your personal data

We use personal data to operate the website, respond to enquiries, collect and pass relevant information to the licensed Turkish clinic for clinical review, receive and communicate provisional treatment-related information and quotations supplied by the licensed Turkish clinic, arrange appointments, coordinate bookings, liaise with Avangart Clinic Turkey and licensed Turkish clinics, pass relevant information to clinicians for review, communicate before and after booking, process payments, issue invoices, manage refunds, deal with reviews or complaints, provide aftercare communication, maintain records, comply with legal obligations, protect patient safety, manage disputes, enforce our terms and conditions, improve our referral, booking and communication services, and maintain website security.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on what services, information or offers may be relevant to you. This is how we decide which communications may be of interest to you.

You may receive marketing communications from us if you have requested information from us or used our referral, booking or communication services and you have not opted out of receiving that marketing, where this is permitted by law.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of an enquiry, booking, treatment-related communication, payment, aftercare request, complaint or other non-marketing transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy.

This may include Avangart Clinic Turkey, licensed Turkish dental clinics, dentists, doctors, oral surgeons, dental nurses, patient coordinators, dental technicians, laboratories, IT providers, website providers, cloud storage providers, email providers, messaging providers, payment providers, banks, accountants, auditors, legal advisers, insurers, hotels, transfer providers, business partners, public authorities, courts, regulators, tax authorities, law enforcement agencies and healthcare authorities where necessary and lawful.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may share your personal data in a way that involves transferring your data outside the UK, including to Türkiye. This may be necessary to respond to enquiries, pass information to the licensed Turkish clinic for assessment of treatment suitability, receive and communicate provisional treatment-related information or quotations supplied by the licensed Turkish clinic, coordinate bookings, liaise with Avangart Clinic Turkey and licensed Turkish clinics, arrange treatment-related facilitation services, maintain records, provide aftercare communication, process payments, operate IT systems and comply with legal obligations.

Whenever we transfer your personal data out of the UK, we will take steps required by applicable data protection law so that an appropriate level of protection is afforded to it. Depending on the circumstances, this may include at least one of the following safeguards:

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
We may use specific contracts approved for use in the UK or other lawful transfer mechanisms, including standard contractual clauses, explicit consent where required, contractual safeguards, technical and organisational security measures, or another lawful mechanism permitted by applicable law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for website operation, enquiry handling, booking, treatment-related assessment, clinical record keeping where applicable to information shared with us, aftercare communication, complaints, tax, accounting, regulatory obligations, insurance matters, legal claims and enforcement of terms and conditions. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Clinical records, health data, treatment records, identity and contact information linked to treatment, and transaction records linked to treatment may be retained for 20 years from the treatment relationship unless a longer period is required or permitted by law. Website enquiry data that does not lead to treatment may be kept for a shorter period unless it is needed for legal, regulatory, complaint, business record, audit, patient safety or dispute purposes.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary to find out more about your legal rights. Where Turkish PDPL/KVKK applies, you may also have rights under Article 11 of Law No. 6698, including the right to learn whether your personal data is being processed, request information about processing, learn the purpose of processing and whether the data is being used in accordance with that purpose, know the third parties to whom data has been transferred, request correction or deletion where applicable, request notification of correction or deletion to third parties where applicable, object to results produced exclusively by automated processing, and claim compensation where damage is suffered due to unlawful processing.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month, unless a different period applies under the relevant law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to operate the website, respond to enquiries, provide an effective referral, communication and booking service, coordinate non-clinical treatment-related arrangements with Avangart Clinic Turkey and licensed Turkish clinics, protect patient safety, manage disputes and maintain a secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors based in the UK, Türkiye, the EEA or outside the EEA.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, Türkiye, the EEA or outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK, Türkiye or elsewhere where applicable.
Avangart Clinic Turkey, licensed Turkish dental clinics, dentists, doctors, oral surgeons, dental nurses, dental technicians, laboratories, payment providers, accommodation providers, transfer providers, communication providers and other providers of services relevant to your enquiry, booking, treatment-related arrangements or aftercare.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) If you want us to establish the data’s accuracy. (b) Where our use of the data is unlawful but you do not want us to erase it. (c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. (d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.