GDPR / KVKK Notice

1. Data Controller

Entity: Opinion Sağlık Teknoloji Yatırımları A.Ş. (Opinion AI)
Address: Salacak Mah. Öğdül Sok. No: 29b Suite: 6, Üsküdar / Istanbul / Türkiye
Email: info@opinionmina.com
Data protection requests: destek@opinionmina.com

2. Important Distinction: Data on Platforms Built on MINA vs Website Data

For data processed within Opinion AI's platforms built on MINA (TIS, SIT-H, SIT-I, SIT-G), the "data controller" role belongs to the institution (hospital / insurance company). Opinion AI does not take this data into its own systems or store it; it remains on the institution's own infrastructure. If installation, maintenance or support requires access to data, Opinion AI acts as a data processor on the institution's instructions and under a data processing agreement.

This Notice covers only personal data processed in the context of opinionmina.com website usage.

3. Categories of Personal Data Processed

• Identity data: name, surname
• Contact data: email, phone (if shared via form)
• Professional data: company, role (in contact form)
• Technical / security data: IP address, browser data, visit logs
• Cookie data: technical and analytical cookies

4. Purposes of Processing

• To respond to your contact requests
• To provide information about services you request
• To secure our website and manage our technical infrastructure
• To meet legal obligations
• To improve our services (statistical analysis)

5. Legal Bases for Processing

• KVKK Art. 5/2-c / GDPR Art. 6(1)(b): Necessary for the performance of a contract (responding to contact requests)
• KVKK Art. 5/2-ç / GDPR Art. 6(1)(c): Compliance with a legal obligation
• KVKK Art. 5/2-f / GDPR Art. 6(1)(f): Legitimate interests (security, statistics)
• KVKK Art. 5/1 / GDPR Art. 6(1)(a): Explicit consent (only with your opt-in for marketing content)

6. Data Transfers

Your data may be shared with:

• Competent public authorities when required by law
• Technical infrastructure providers we use, limited to functional purposes and under contractual confidentiality: server hosting (Amazon Web Services), email delivery (Resend), cookie consent management (Secure Privacy) and, if you consent, website analytics (Google Analytics)

International transfers: Some of the companies that host our website and provide email delivery, cookie consent management and website analytics are based outside Türkiye. These transfers are made under the conditions and safeguards set out in KVKK Art. 9 and, where applicable, GDPR Chapter V.

7. Methods of Collection

Your data is collected electronically through contact forms on our website, email correspondence, and automated technical systems (cookies, server logs).

8. Data Subject Rights (KVKK Art. 11 / GDPR Chapter III)

Under KVKK and GDPR you have the following rights:

1. Learn whether your personal data is processed
2. Request information about its processing
3. Learn the purpose of processing and whether it is used in line with that purpose
4. Know the third parties to whom data is transferred at home or abroad
5. Request rectification if processed incompletely or incorrectly
6. Request erasure, destruction or anonymization in accordance with KVKK Art. 7 / GDPR Art. 17
7. Request that the actions taken be notified to third parties to whom data was transferred
8. Object to results from solely automated decision-making
9. Claim compensation for damages from unlawful processing

9. How to Submit a Request

To exercise the above rights, please send a written request to destek@opinionmina.com. Your request must:

• Be made in Turkish or English
• Include your name, surname and identity verification information
• Clearly state your request

Requests are answered free of charge within 30 days under KVKK Art. 13. If processing entails a separate cost, the tariff determined by the Authority may apply.

10. Data Security Measures

• AES-256 encryption (at rest)
• TLS 1.3 (in transit)
• Role-based access control (RBAC) and multi-factor authentication
• Regular security audits and penetration tests
• ISO/IEC 27001 and 27701 certified information security management system