Privacy Policy
Effective Date: December 10, 2019
Privacy Commitment
Thank you for visiting https://sule-hairtransplant.com (“Website”), owned and operated by Özel Şule Clinic Polikliniği (“Clinic”, “we”, “us”, or “our”). We respect your privacy and are fully committed to protecting your personal information.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our Website or our clinic. By accessing or using our Website, you acknowledge that you have read and understood this Privacy Policy.
If you do not agree with the terms described here, please refrain from providing personal data or using the Website.
1. Data Controller
Clinic Name: Özel Şule Clinic Polikliniği (Sule Hair Clinic)
Address: Yeşilpınar, Çay Sk. No:2, 34065 Eyüpsultan, İstanbul / Turkey
E-mail: info@sule-hairtransplant.com
Website: https://sule-hairtransplant.com
2. Categories of Personal Data We Collect
Identity & Contact Data: Name, surname, email, phone
Medical Data: Hair loss history, previous treatments, health conditions, medications, allergies, surgeries (special category data under GDPR, sensitive data under KVKK)
Transaction Data: Appointment date, package selection, payment/deposit details
Usage Data: Website usage, cookies, analytics, IP address, device info
Marketing Data: How you heard about us, preferences, consents
3. Purposes of Processing
To provide medical evaluation and treatment planning
To book and manage appointments
To communicate with patients (WhatsApp, e-mail, phone)
To ensure compliance with medical and legal obligations
To improve services and patient experience
To manage marketing and outreach (only with explicit consent)
4. Legal Basis
GDPR: Art. 6(1)(a) consent, Art. 6(1)(b) contract, Art. 6(1)(c) legal obligation, Art. 6(1)(f) legitimate interest. For health data: Art. 9(2)(a) explicit consent, Art. 9(2)(h) medical purposes.
KVKK: Art. 5(1) explicit consent, Art. 5(2) legal bases (e.g. performance of contract, legal obligation), Art. 6(2) explicit consent for health data.
5. Data Sharing
Your data will never be sold to third parties. Data may only be shared with:
Authorized doctors, anesthesiologists, medical staff
IT providers, hosting companies, communication tools (WhatsApp Business, CRM, email services)
Public authorities, only where legally required
6. International Data Transfers
If your data is transferred abroad (e.g. cloud hosting outside Turkey/EU):
GDPR: Standard Contractual Clauses (SCCs) or adequacy decisions are applied
KVKK: Your explicit consent is obtained or KVKK Article 9 exceptions are applied
7. Data Retention
Medical data: retained for 10 years as required by Turkish health law, unless earlier deletion is legally possible
Contact & appointment data: retained for the duration of the relationship + 2 years
Marketing consents: until withdrawn
Analytics/cookie data: as specified in the Cookie Policy
8. Rights of Data Subjects
Under GDPR and KVKK, you have the right to:
Access your data
Rectify or update data
Request erasure (“right to be forgotten”)
Restrict or object to processing
Data portability (GDPR only)
Withdraw consent at any time
File a complaint with the Turkish Data Protection Authority or an EU supervisory authority
Requests can be sent to: info@sule-hairtransplant.com
9. Security Measures
Encrypted storage of medical data
Restricted access to authorized staff only
Secure servers and firewall protection
Regular monitoring and updates
10. Cookies & Tracking
We use cookies to improve user experience, analytics, and security
Marketing cookies are only used with your consent
You can manage cookie settings through your browser or site preferences
11. Updates to Policy
We may update this policy from time to time.
12. Contact Us
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:
Özel Şule Clinic Polikliniği (Sule Hair Clinic)
Address: Istanbul, Turkey
E-mail: info@sule-hairtransplant.com
Phone: +90 545 674 31 91
By using our Website, you signify your consent to the terms of this Privacy Policy.
Last Updated: September 22, 2025