Privacy Policy
Last updated: 13 October 2025
This Privacy Policy explains how YHTT processes your personal data when you visit our site, contact us, or share information (including medical photos) for introduction to our partner Clinics.
Important: Health-related photos and information are special category data under GDPR/UK GDPR and sensitive personal data under KVKK. We treat them with heightened care and only process/share them with your explicit consent.
1) Who is the controller?
2) What data we collect
- Contact data: name, email, phone, country/region.
- Inquiry details: your goals, prior treatments, preferred dates, budget.
- Hair related data (special category): photos of scalp/hair, medical history you choose to share or asked by the clinic.
- Technical data: device, browser, IP address, language, country, cookie IDs, pages viewed, referral source.
- Communications: emails, form submissions, message logs.
- Clinic interaction data: which Clinic we referred you to, referral timestamps, follow-up status (non-medical).
We
do not require national IDs or payment details on our site.
3) Why we process your data (purposes & legal bases)
| Purpose |
Examples |
Legal basis |
| Handle your enquiry & introduction to Clinics |
Respond to forms/emails; share details with Clinics you select |
GDPR Art. 6(1)(b) steps prior to a contract (on request) and Art. 6(1)(f) legitimate interests (efficient referrals) |
| Process & share health photos/info |
Forward to Clinics for a preliminary suitability assessment |
GDPR Art. 9(2)(a) explicit consent; KVKK explicit consent |
| Communicate with you |
Scheduling, updates, feedback |
Art. 6(1)(b) or Art. 6(1)(f) |
| Improve & secure our site |
Analytics, troubleshooting, preventing abuse |
Art. 6(1)(f) |
| Legal & compliance |
Record-keeping, responding to lawful requests |
Art. 6(1)(c) legal obligation; Art. 6(1)(f) |
Where consent is required (e.g., for special-category data and for non-essential cookies/marketing), we’ll ask you clearly and allow you to withdraw at any time.
4) Sharing your data
We share your data only as needed:
- Clinics (independent controllers): We send your enquiry and any photos only with your request/consent. Clinics then process your data under their own privacy notices.
- Service providers (processors): secure hosting, email infrastructure, CRM, analytics, security/anti-spam tools, form processing, file storage. They act on our instructions under data-processing agreements.
- Legal/Compliance: courts, regulators, law enforcement where required.
We
do not sell your personal data.
5) International transfers
- Our platform operates from Türkiye. If you are in the EEA/UK, your data may be transferred to Türkiye and other countries without an EU/UK adequacy decision.
- For transfers from the EEA/UK to countries without adequacy, we rely on appropriate safeguards (e.g., EU/UK Standard Contractual Clauses) and implement additional measures (encryption in transit and at rest, strict access control).
- Clinic-direct communications may involve your direct transfer to Türkiye; once data is with a Clinic, it is handled under the Clinic’s own legal obligations (including KVKK).
6) Retention
- Enquiry data: typically 24 months from last interaction, then securely deleted or anonymized.
- Special-category photos: 12 months from collection unless you ask us to delete sooner or continued processing is necessary (e.g., active referral), after which we delete or irreversibly blur/anonymize.
- Technical logs: 12 months (security/anti-fraud). We may retain minimal records as required by law or to establish/defend legal claims.
7) Your rights
Depending on where you live, you may have rights to
access,
rectify,
erase,
restrict,
object,
portability, and to
withdraw consent at any time (without affecting past lawful processing).
- EEA/UK: GDPR/UK GDPR rights + right to complain to your data protection authority.
- Türkiye: KVKK rights to apply to the data controller and to the Personal Data Protection Authority. To exercise rights, email [info@yourhairtransplantturkey.com]. We may need to verify your identity.
8) Security
We use technical and organizational measures such as strict role-based access, audit logging, and regular reviews. No system is 100% secure; please avoid sending more sensitive data than necessary.
9) Children
Our services are
not for individuals under 18. We do not knowingly collect children’s data.
10) Direct communications with Clinics
Once we introduce you, you may communicate directly with a Clinic (email, phone, WhatsApp, etc.). Those communications are governed by the Clinic’s privacy policy. We are not responsible for a Clinic’s handling of your data after transfer.
11) Marketing
We only send marketing with your
opt-in consent. You can opt out at any time (unsubscribe link or by contacting us). Service/transactional messages are not marketing.
12) Cookies & similar tech
See our
Cookie Policy below for details of cookies we use and how to control them.
13) Changes
We may update this Policy. We’ll post the new version with a new “Last updated” date and, where appropriate, notify you.
14) Contact
Questions or requests:
[info@yourhairtransplantturkey.com]