Privacy Policy

Turkus Hair Transplant Clinic respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, submit forms, request a consultation, download materials, or contact us.

The controller of your personal data is Turkus Hair Transplant Clinic, ul. Białej Floty 8/U2, 02-654 Warsaw, Poland.

For privacy matters and the exercise of your GDPR rights, you can contact us by email at info@turkusclinic.pl or by phone at +48 728 881 118.

We have not appointed a Data Protection Officer. GDPR-related matters can be addressed using the contact details above.

We may collect:

• Full name
• Email address
• Phone number
• Consultation details
• Information about hair loss
• Photos submitted for assessment
• Messages submitted through contact forms
• Technical and analytics data
• Information about how you use the website

We may also receive data that you provide through contact forms and Meta advertising forms (Facebook and Instagram Lead Ads), including your full name, phone number, email address, and responses provided in the form.

Your data may be used for:

• Responding to consultation requests
• Contacting you regarding our services
• Assessing submitted photos
• Providing recommendations regarding hair transplantation
• Improving our services and website
• Providing educational content
• Sending information about the clinic
• Sending promotional offers and marketing communications
• Complying with legal obligations

Depending on the purpose of processing, we rely on the following legal bases under the GDPR:

Article 6(1)(b) GDPR, where processing is necessary to respond to your consultation or service request or to take steps at your request before entering into a contract.

Article 6(1)(a) GDPR, where you have given consent, including for marketing communications and analytics technologies that require consent.

Article 6(1)(c) GDPR, where processing is necessary to comply with a legal obligation.

Article 6(1)(f) GDPR, where processing is necessary for our legitimate interests, such as maintaining the security and proper operation of our website, improving our services, or establishing, exercising, or defending legal claims, provided that your rights and interests do not override those interests.

Where submitted photos, information about hair loss, or other consultation information constitutes health data or other special-category personal data, we process such data on the basis of your explicit consent under Article 9(2)(a) GDPR, unless another applicable legal basis under Article 9 GDPR applies.

Submitting a consultation request or providing your contact details does not by itself constitute consent to receive marketing communications.

We may contact you without separate marketing consent where this is necessary to respond to your consultation request, provide requested information, or communicate with you regarding services you have asked about.

Where you separately consent to marketing communications, Turkus Hair Transplant Clinic may contact you regarding:

• Educational content
• Clinic updates
• Information about services
• Promotional offers and marketing communications

You may withdraw your marketing consent and unsubscribe from marketing communications at any time.

Photos submitted through our website are used solely for consultation, assessment, treatment planning, and related communication.

Photos will never be published publicly or used in marketing materials without your explicit, separate consent.

Access to photos is limited to authorized persons on the clinic's side (including consultation coordinators and doctors) and technical providers necessary to operate the form.

Technically, photos may be processed by Supabase Inc. (database for form inquiries) and Resend Inc. (delivery of emails with attachments to the clinic's inbox). These providers act as processors and may not use the photos for their own purposes.

If we do not begin treatment, we generally delete or anonymize photos within 24 months of the last contact, unless you request deletion earlier. If you become a patient, the retention period may be longer where required by medical or legal obligations.

To request deletion of photos or other form data, email info@turkusclinic.pl from the email address provided in the form (or describe your request if you no longer have access to that address). We will respond within 30 days.

We do not sell personal data.

Information may only be shared with trusted service providers necessary for operating the website, processing forms, email communication, analytics (with consent), and clinic operations. Our main providers include:

Supabase Inc. (database: form inquiries, cookie consent logs).

Resend Inc. (sending emails to the clinic and confirmations to users).

Vercel Inc. (website hosting; Vercel Web Analytics only with your analytics consent).

Google Ireland Ltd. / Google LLC (Google Analytics 4, only with consent).

Microsoft Corporation (Microsoft Clarity, only with consent).

Some providers may process data outside the European Economic Area (for example, in the United States), subject to legally required safeguards such as Standard Contractual Clauses.

We retain data only for as long as necessary for the purposes described in this policy:

• Form inquiries (contact details, message, photos): up to 24 months from the last contact, unless you request deletion earlier or a longer period results from the patient-clinic relationship or applicable law.
• Cookie consent logs (anonymous identifier, choice, policy version, language, page path, user agent): up to 3 years from the date the choice was recorded, for GDPR accountability purposes.
• Analytics data (Google Analytics, Microsoft Clarity, Vercel Web Analytics): according to the settings of those tools, only where you have consented to analytics.
• Email correspondence concerning privacy matters and the exercise of rights: up to 3 years after the matter is closed, unless the law requires a longer period.

After the retention period expires, data is deleted or anonymized unless the law requires further retention.

We use essential technologies necessary for the operation of the website and analytics tools that are activated only after obtaining your consent.

We may use:

Google Analytics 4 (Google Ireland Ltd. / Google LLC): measurement of traffic, pages, and conversions.

Microsoft Clarity (Microsoft Corporation): heatmaps and anonymized session recordings that help improve website usability. Form fields containing personal data are masked.

Vercel Web Analytics (Vercel Inc.): aggregated performance and traffic data without traditional advertising cookies.

You can change your cookie choices at any time through the cookie settings in the website footer. Choosing Essential disables analytics tools.

We record each choice in our systems for GDPR accountability purposes: anonymous consent identifier, date, choice (analytics yes/no), policy version, language, page path, and user agent. This is not a user account.

• Improving website functionality
• Measuring website performance
• Analyzing visitor behavior
• Improving the user experience

We use reasonable technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or loss.

You have rights under the GDPR. You may request:

• Access to your personal data
• Correction of inaccurate data
• Deletion of personal data
• Restriction of processing
• Withdrawal of consent (for example, for cookie analytics or marketing where processing is based on consent)
• Data portability, where applicable
• Objection to processing, where applicable

You can exercise your rights by sending a request to info@turkusclinic.pl. We generally respond within 30 days.

You also have the right to lodge a complaint with the supervisory authority: President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl.

Turkus Hair Transplant Clinic, ul. Białej Floty 8/U2, 02-654 Warsaw, Poland.

Email: info@turkusclinic.pl

Phone: +48 728 881 118

Contact form: turkusclinic.pl/kontakt