PRIVACY NOTICE REGARDING THE PROCESSING OF PERSONAL DATA
Last Updated: 1.1.2024
Dear Concerned,
This Privacy Notice hse been prepared by Merck Sharp Dohme İlaçları Limited Şirketi (“MSD”) a company located in Turkiye, in its capacity as the data controller, in accordance with the Personal Data Protection Law No. 6698 (“DPL”) to inform you about the processing and transfer of personal data related to patients. The protection of your personal data and the preservation of your privacy are among our primary priorities as MSD.
What Types of Personal Data Do We Process?
This Privacy Notice covers your personal data (hereinafter referred to as “Personal Data”) , including
- your identity and contact information such as your name, surname, email address and phone number, your notifications related to MSD products and services, legal transaction data related to your interactions with us, including your consents and approvals provided under DPL or other relevant legislation, and other non-sensitive personal data that you may share with us while using our communication platforms and
- information you will share with us regarding your illness, your adverse event notifications related to MSD products, your quality complaints regarding our products and services, and other complaints, constitutes the health data, which is classified as sensitive data (after referred to as “Health Data”).
Which Methods Do We Collect Your Personal Data?
We collect your Personal Data that you share with us through our websites online. Additionally, within the scope of your communications with MSD, if necessary for our data processing purposes, we may also collect your Personal Data from you through automatically or non-automatically means either in written or verbal form. If necessary, in accordance with the legislation and subject to your consent, we may also collect your Personal Data from your doctor by contacting your doctor in writing or verbally.
For What Purposes and Legal Grounds Do We Process Your Personal Data?
Processing of Non-Sensitive Personal Data
Your Personal Data, excluding Health Data, may be processed for the following purposes and based on the following legal grounds:
- To evaluate your requests, inquiries, and opinions, considering your purpose of contacting us, to respond to your notifications and medical information
requests regarding MSD products and services, to take necessary actions in this regard, to communicate with you on these matters and to provide you with a response, - To record your consents given within the scope of processing purposes requiring explicit consent, to disclose your Personal Data to official authorities if
requested in accordance with the relevant legislation and in cases where it is mandatory to disclose to official authorities due to the mandatory legal provisions of the applicable legislation, to use your Personal Data to the extent necessary in relation to any applications you may submit to MSD or any legal dispute affecting MSD or potential legal disputes, as well as to share it with courts and other competent authorities and organizations.
Your personal data may be processed within the scope of our legitimate interests for the purposes specified above, provided that it does not harmed your fundamental rights and freedoms, pursuant to Article 5/2(f) of the DPL, to fulfill MSD’s legal obligations pursuant to Article 5/2(c) of the DPL, and to establish or protect MSD’s rights pursuant to Article 5/2 (e) of the DPL, and may be transferred to third parties pursuant to Article 8/2(b) of the DPL.
Processing of Your Health Data
We can only process your Health Data if you give explicit consent for the following purposes:
- To contact you in order to better analyze your question and the problems you encounter with our products and services and to provide you with a response,
- Feedback, adverse event notifications, complaints, and other inquiries regarding the MSD products and services you use for your illness will be recorded, monitored, reported to the Ministry of Health, and shared with other MSD entities providing the relevant product and service by anonymizing or pseudonymizing it so that it does not directly identify you, for the purpose of improving the relevant product or service,
- To process your adverse event notifications, to fulfill obligations related to product safety.
To Whom and For What Purposes Can We Transfer Your Personal Data Domestically?
If necessary to fulfill the purposes specified above, your Personal Data, including Health Data you have provided to MSD, may be shared with your physician, healthcare professionals we collaborate with to evaluate incoming requests, other consultants, and hosting/archiving and technology companies to ensure the secure storage of all information you share with us and to communicate with you through our website and other communication channels. Your Personal Data may also be shared with our lawyers, judicial and administrative authorities, if required for the purposes specified above and only to the extent necessary.
Transfer of Your Personal Data Abroad and Legal Ground:
Your Personal Data may be transferred abroad, subject to your explicit consent pursuant to Article 9/1 of the DPL only if necessary for the purposes specified above
- to companies located abroad and within the group of companies including MSD,
- to third parties and business partners located abrod from whom MSD receives services/support/consultancy,
- due to MSD being part of a global corporate group, to countries where the the databases and servers used electronically by MSD or its corporate business partners are located.
We would like to remind you that MSD websites are also provided through a website hosted abroad. All data you share through MSD websites are automatically transferred abroad.
Your Rights and Applications Regarding Your Personal Data
You have legal rights under Article 11 of the DPL, and you may contact us using the contact information provided below when you wish to exercise these rights:
Merck Sharp Dohme İlaçları Limited Şirketi
Esentepe Mah. Büyükdere Caddesi No:199 Levent 199 Ofis Bloğu Kat:13 34394 Levent/ Istanbul
Tel: 0212 336 1000 Fax: 0212 355 0202