PRIVACY NOTICE REGARDING THE PROCESSING OF PERSONAL DATA
Last Updated: 1.1.2024
Dear Healthcare Professional;
This Privacy Notice hase 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 healthcare professionals. 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”) such as your name, surname, email address, phone number, profession, your notifications related to MSD products and services, and medical information requests, consents and approvals you provide under DPL or other relevant legislation, as well as other non-sensitive personal data that you may share with us while using our communication platforms.
Information you will share with us regarding your patient, such as adverse event notifications related to MSD products, quality complaints about our products and services, and other complaints, constitutes the patient’s health data which is classified as sensitive personal data. Before sharing your patients’ data with us, we kindly ask you to review the privacy notice prepared specifically for patients using MSD products and services, inform your patient about this privacy notice, and confirm that your patient agrees to share their personal data with us.
Which Methods Do We Collect Your Personal Data?
We collect your Personal Data that you will share with us while contacting us through our websites, online through our website.. Additionally, depending on your interaction with MSD, we may collect personal data during visits made by MSD employees to you within the scope of this Privacy Notice. Finally, if necessary for our data processing purposes within the scope of your communications with MSD, we may also collect your Personal Data from you through automatically or or non- automatically means either in written or verbal form.
For What Purposes and Legal Grounds Do We Process Your Personal Data?
Your Personal Data may be processed for the purposes and legal grounds specified below:
- To evaluate your requests, inquiries, and opinions considering your purpose of contacting us, to respond to your notifications and medical information requests related to MSD products and services, to take necessary actions in this regard, to communicate with you on these matters and to proivde you with a response,
- To evaluate the opinions of healthcare professionals regarding the information, promotional, and training activities conducted by MSD in accordance with the relevant legislation, to conduct analyses to ensure the effectiveness of the information and responses we provide, as well as our activities, to identfy the requests and needs of healthcare professionals, to anonymize incoming requests and inquiries resulting from these analyses, and to assess the anonymized outputs for the purpose of planning potential services tailored for healthcare professionals,
- To the extent applicable, to invite you to domestic and international congresses and product promotion meetings organized by or sponsored by MSD, to contact you for this purpose, andto make the necessary arrangements if you participate in such congresses and meetings.
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) pf the DPL, and may be transferred to third parties pursuant to Article 8/2(b) of the DPL.
We may process your Personal Data without your explicit consent within the scope of Article 5/2(c) of the DPL to record, monitor, and report adverse event notifications that you may make as a healthcare professional through our websites to fulfill MSD’s legal obligations.
Additionally, your Personal Data may be disclosed to official authorities without your explicit consent if requested by official authorities in accordance with the relevant legislation and when required by mandatory legal provisions of the applicable legislation. Your Personal Data may also be used and shared with courts and other competent authorities and organizations to the extent necessary in relation to applications you may submit to MSD or legal disputes affecting MSD or potential disputes. In this context, your Personal Data may be processed without your explicit consent within the scope of Article 5/2 (ç) of the DPL for the purpose of fulfilling MSD’s legal obligations and within the scope of Article 5/2 (e) of the DPL for the purpose of establishing or protecting MSD’s rights.
Finally, your Personal Data may also be processed, subject to your explicit consent under Article 5/1 of the DPL, to extent permitted by applicable legislation, for the purposes of preparing and delivering printed communication materials, conducting marketing communications, including sending commercial electronic messages in accordance with the Law on the Regulation of Electronic Commerce, , sending promotional materials and newsletters, informing you about various activities such as courses, scientific and educational meetings, congresses, and conferences that have been organized or planned to be organized in the future. In this context, if you give your consent to receiving commercial communication from MSD, your preferences regarding commercial communication (such as consent, exercising the right to opt-out, etc.) will be notified to the Commercial Communication Management System (İYS) established under the Regulation on Commercial Communication and Commercial Electronic Messages, transferred to İleti Yönetim Anonim Şirketi established by the Union of Chambers and Commodity Exchanges of Turkey (TOBB), and processed in accordance with the general privacy notice on the protection and processing of personal data prepared by İleti Yönetim Sistemi Anonim Şirketi (available at https://iys.org.tr and https://iys.org.tr/iys/kvkk-ve-gizlilik ) as required by the legislation.
To Whom and For What Purposes Can We Transfer Your Personal Data Domestically?
If necessary to fulfill the purposes specified above, your Personal Data provided to MSD, may be shared with third- party companies and suppliers with whom we receive services/consultancy, including our business partners and travel agencies located domestically. Your Personal Data may also be shared with judicial and administrative authorities if necessary for the purposes specified above. If you give your consent to commercial communication, your Personal Data may also be shared with İleti Yönetim Sistemi Anonim Şirketi to the extent necessary to fulfill our legal obligations and to establish/protect our rights.
Transfer of Your Personal Data Abroad and Legal Ground:
Your Personal Data may be transferred, 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 abroad from whom MSD receives services/support/consultancy,
- due to MSD being part of a global group of companies, to countries where 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 is 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 Ltd. Şti.
Esentepe Mah. Büyükdere Caddesi No:199 Levent 199 Ofis Bloğu Kat:13 34394 Levent/ Istanbul
Tel: 0212 336 1000 Fax: 0212 355 0202