This Explicit Consent Form explains the purposes and scope of specific activities in which Özel Lotus İstanbul Ağız ve Diş Sağlığı Polikliniği may process your personal data where your explicit consent is required under Turkish Personal Data Protection Law No. 6698 (KVKK).
Explicit consent must relate to a specific matter, be informed and be freely given. It is therefore not a blanket authorisation covering every activity involving the processing of your personal data.
1. Data Controller
The data controller for the personal data processing activities covered by this form is Özel Lotus İstanbul Ağız ve Diş Sağlığı Polikliniği.
For detailed information about how your personal data is processed, please read our Personal Data Protection Notice .
2. The Difference Between Providing Information and Obtaining Explicit Consent
Under the KVKK, the obligation to provide information and the process of obtaining explicit consent are distinct legal processes.
The obligation to provide information means explaining how your personal data is processed. It does not depend on your approval.
Explicit consent is requested only where it is required as the legal basis for the relevant processing activity.
Data processing activities that do not legally require explicit consent for the provision of healthcare are not made conditional on your consent.
Declining to give explicit consent does not prevent you from receiving essential healthcare services that can be provided on another lawful basis under the applicable legislation.
3. Health Data and Treatment
Health data is classified as a special category of personal data under the KVKK.
When providing oral and dental healthcare, personal and health data necessary for diagnosis, treatment and care, patient safety and compliance with obligations under healthcare legislation may be processed on an appropriate lawful basis provided for in the KVKK.
Accordingly, routine patient registration, examinations, diagnosis, treatment, treatment planning and healthcare activities that do not legally require explicit consent are not conditional on the optional consent described in this form.
4. Activities That May Require Explicit Consent
Depending on the nature of the processing activity carried out at our clinic, your explicit consent may be requested separately for specific activities where no other appropriate lawful basis under the KVKK applies.
These activities may primarily include the following:
5. Data That May Be Processed on the Basis of Explicit Consent
Depending on the activity requiring consent, the relevant categories of personal data listed below may be processed solely for the specified purpose:
- First and last name
- Telephone number
- Email address
- Communication preferences
- Photographs and video recordings
- Intraoral or extraoral visual recordings
- Website usage and interaction information
- Cookie and device identifiers
- Other limited personal data required for the relevant activity
Where a specific activity requires health data to be processed on the basis of explicit consent, a separate consent request clearly identifying the health data and its intended use will be provided.
6. Key Principles of Explicit Consent
The following principles apply to ensure that your explicit consent is lawful:
6.1. Consent Must Be Specific
Explicit consent must be specific enough for you to understand which personal data will be processed and for what purpose.
General, unlimited statements such as “I agree to the processing of all my personal data for any purpose” are not used.
6.2. Consent Must Be Informed
Before your consent is obtained, you must receive clear information about the processing activity, the personal data involved and the purpose of processing.
6.3. Consent Must Be Freely Given
Your explicit consent must be given freely, without pressure, coercion or misleading information.
Essential healthcare services that do not legally require explicit consent are not made conditional on your agreement to an optional processing activity.
7. Separate Consent Choices
As far as possible, processing activities with different purposes are not combined under a single general consent.
For example, the following choices may be considered independently:
- Use of photographs or videos for promotional purposes
- Marketing communications by email
- Marketing communications by SMS or telephone
- Use of analytics cookies
- Use of advertising and marketing cookies
- Specific activities involving international data transfers that require explicit consent
This allows you to authorise only the processing activities you choose.
8. Use of Photographs and Videos
Visual records that are medically necessary for examinations, diagnosis, treatment planning or follow-up serve a different purpose from visual records intended for promotion or publication.
If patient photographs or videos are intended for use:
- on the website,
- on social media accounts,
- in promotional materials,
- in advertising,
- in educational activities or presentations,
the applicable lawful basis is assessed separately. Where required, separate explicit consent is obtained, clearly specifying the purpose and scope of use.
Recommended approach: For the promotional use of patient photographs and videos, it is more appropriate to use a separate “Explicit Consent Form for Visual Recording and Publication” in addition to this general page.
9. Promotional and Marketing Communications
Where using your contact details for promotion, campaigns, announcements or marketing requires explicit consent, your consent is obtained separately for that activity.
Appointment confirmations, communications about ongoing treatment, responses to enquiries initiated by patients and legally required notifications are considered separately from marketing communications.
The permissions and obligations required under the applicable electronic communications legislation also apply to the sending of commercial electronic messages.
10. Cookies and Digital Technologies
Where explicit consent is required for analytics, advertising or marketing technologies that are not essential to the website’s operation, those technologies are not activated until the user has made the required choice.
Cookie preferences can be managed individually through the website’s cookie settings panel.
For more information, please read our Cookie Policy .
11. Sharing Personal Data
For a specific processing activity based on your explicit consent, your personal data may be shared with necessary third parties where the activity requires it, solely for the relevant purpose.
Depending on the activity, these may include:
- technical service providers,
- digital communications providers,
- analytics service providers,
- advertising and marketing platforms,
- media or content service providers
.
The scope of any transfer and the categories of recipients are assessed separately for the specific activity for which consent is requested.
12. International Data Transfers
Some digital services or technology providers use infrastructure located outside Türkiye, which may involve transferring personal data abroad.
Where an international transfer is involved, the availability of an adequacy decision, appropriate safeguards or other lawful transfer mechanisms under Article 9 of the KVKK is assessed first.
If a specific transfer requires explicit consent, you will receive separate information about the nature of that transfer before your consent is requested.
13. Retention Period
Personal data processed on the basis of explicit consent is retained for the period required by the relevant purpose or until you withdraw your consent, taking into account any applicable statutory retention obligations.
When the processing purpose no longer applies, consent is withdrawn or the legal basis requiring retention ceases to exist, personal data is deleted, destroyed or anonymised in accordance with the applicable legislation.
14. Withdrawing Explicit Consent
You may withdraw your explicit consent at any time.
Withdrawal takes effect prospectively. Once the data controller receives your withdrawal request, the relevant processing activity is stopped if it relies solely on explicit consent and no other lawful basis applies.
Withdrawal does not affect the lawfulness of processing carried out on the basis of your explicit consent before the date of withdrawal.
Withdrawing your explicit consent must not prevent the provision of essential healthcare services.
However, the optional service or processing activity covered by the withdrawn consent may no longer be available.
15. Giving Explicit Consent
For an activity requiring explicit consent, your consent is obtained separately for that specific activity after you have received the necessary information about the processing involved.
Consent may be given electronically by ticking an initially unticked checkbox, actively choosing an option in a preferences panel or making a similar affirmative statement.
Pre-ticked boxes, silence or inaction must not be treated as explicit consent.
16. Use in Website Forms
Where explicit consent is required on the DentLotus website, separate consent checkboxes may be provided for the relevant purposes.
For example, where an activity requires explicit consent, the choice may be presented in wording similar to the following:
“I have read the Explicit Consent Form and give my explicit consent to the specified optional personal data processing activity.”
A single checkbox must not be used to cover all unrelated processing purposes. Separate choices are provided for different purposes where necessary.
17. Requests and Contact
To withdraw your explicit consent, obtain information about your personal data or exercise your rights under the KVKK, you may contact the data controller, Özel Lotus İstanbul Ağız ve Diş Sağlığı Polikliniği .
Özel Lotus İstanbul Ağız ve Diş Sağlığı Polikliniği
Website: dentlotus.com
Contact: You can reach us through the official contact channels listed on our website.
18. Updates to This Form
This Explicit Consent Form may be updated to reflect changes in personal data processing, the technologies used, the services provided or the applicable legislation.
The current version is published on this page, with the last updated date shown at the top.
If a new processing activity would change the scope of previously obtained consent, that consent is not automatically extended to cover the new activity. New consent is obtained where necessary.