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

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