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FAIR HAIR CLINIC

Privacy Policy

Last updated: 15 May 2026

Fair Hair Clinic respects your privacy. This Privacy Policy explains how personal data may be collected, used, shared and protected when you visit fairhairclinic.com, contact Fair, request a hair analysis, plan treatment, or communicate with our international patient team.

This Policy should be read together with our Cookie Policy and any additional privacy information or consent form provided during medical assessment or treatment.

1. Who this policy applies to

This Policy applies to visitors to the Fair Hair Clinic website and to people who contact Fair for information, submit a Free Hair Analysis, communicate with our patient team, request or arrange treatment, or otherwise provide personal data to Fair in connection with our international patient services.

Different privacy information may apply to clinical records created by the hospital, doctor or other healthcare provider involved in your medical treatment.

2. Who is responsible for your personal data?

For website, enquiry and patient-coordination activities described in this Policy, the data controller is:

  • FAIR HAIR CLINIC ULUSLARARASI SAĞLIK TURİZMİ ORGANİZASYON LİMİTED ŞİRKETİ
  • Trading as: Fair Hair Clinic
  • Istanbul, Türkiye
  • Privacy contact: info@fairhairclinic.com

3. Fair and the treating hospital / medical provider

Fair Hair Clinic coordinates the patient journey and operates the Fair website and international-patient communication.

Hair-transplant procedures take place in a private-hospital environment. The hospital, doctor and/or other licensed healthcare provider may have separate legal responsibilities for clinical records and medical data created or required in connection with diagnosis, consent, treatment, prescriptions, laboratory tests or other healthcare services.

Where Fair sends information to the treating medical team for assessment or treatment, that provider may process the information under its own legal obligations and privacy notice.

4. What personal data may Fair collect?

Depending on how you interact with Fair, we may collect the following categories of personal data:

Identity and contact data

  • name
  • age or date of birth where needed for assessment
  • email address
  • phone / WhatsApp number
  • country of residence
  • preferred language

Enquiry and communication data

  • messages sent through forms, email or WhatsApp
  • questions about treatment, dates, pricing, travel or aftercare
  • communication history with the Fair team

Assessment and health-related data

  • hair-loss history
  • previous hair transplantation
  • medical conditions relevant to treatment suitability
  • medications you tell us about
  • scalp, donor, beard or eyebrow photographs
  • other medical information voluntarily supplied or requested for assessment

Booking and travel data

  • requested or confirmed treatment dates
  • flight details supplied for transfer coordination
  • hotel / transfer information
  • travel-companion information where necessary

Payment and transaction data

  • payment status and transaction references
  • billing / invoice information where required
  • Fair does not aim to store full payment-card data where payment is handled by a payment provider

Technical website data

  • IP address
  • device / browser information
  • website usage and security logs
  • cookie and analytics information, depending on your cookie choices

5. Health data and medical photos

Information about your health, medications, medical history and treatment suitability can be sensitive personal data. Photographs submitted for a hair analysis can also reveal health-related information.

Fair aims to collect only the health information reasonably needed for assessment, coordination, treatment preparation, follow-up or legal obligations.

Where special-category or sensitive personal data require explicit consent or another specific legal condition, Fair processes that data only when the relevant condition under applicable law is met.

Assessment photos are medical-related data. Submitting them for assessment does not automatically give Fair permission to use them for advertising, social media or before-and-after marketing.

6. How do we collect personal data?

Fair may collect personal data:

  • directly from you through the website
  • through the Free Hair Analysis form
  • through WhatsApp, email, telephone or other approved communication channels
  • during booking and patient coordination
  • during follow-up after treatment
  • from the treating hospital or medical team where sharing is necessary and lawful
  • automatically through website security, cookie or analytics technologies

Please do not send unnecessary medical information through the general Contact form. Use the dedicated assessment or patient channel when clinical information is required.

7. Why do we use personal data?

Fair may use personal data for the following purposes:

PurposeWhy
Responding to enquiriesTo answer questions and provide requested information.
Free Hair AnalysisTo review photos and information and provide a preliminary suitability/treatment assessment.
Patient coordinationTo plan dates, communication, travel, transfers, accommodation and the patient journey.
Medical coordinationTo send relevant information to the treating medical team where needed for assessment or treatment.
Payments / administrationTo manage reservations, payments, invoicing, records and related administrative obligations.
Aftercare and follow-upTo support postoperative communication and review progress.
Website securityTo protect the website, users and Fair against fraud, abuse, attacks and technical problems.
Analytics / improvementTo understand website performance where legally permitted and, where required, based on cookie consent.
MarketingTo send promotional messages only where Fair has a lawful basis and any required consent.
Legal claims / complianceTo comply with applicable law and establish, exercise or defend legal rights.

Legal bases

The legal basis depends on the activity and the law that applies. It may include taking steps at your request before entering an agreement, performing an agreement, complying with legal obligations, Fair’s legitimate interests where those interests do not override your rights, your consent, explicit consent for certain sensitive-data processing, healthcare-related legal conditions where applicable, and the establishment or defence of legal claims.

8. Who may we share personal data with?

Fair does not sell personal data.

Where necessary and lawful, data may be shared with categories of recipients such as:

  • the private hospital, doctor, anaesthesia team or other healthcare professionals involved in assessment or treatment
  • Fair employees and authorised patient coordinators who need the information for their role
  • hotel and transfer providers, limited to the information required to provide the booked service
  • payment, banking or transaction providers
  • website hosting, CRM, email, cloud-storage, cybersecurity and IT service providers
  • communication platforms such as WhatsApp / Meta where you choose or agree to communicate through them
  • analytics or advertising providers where enabled and legally permitted
  • professional advisers such as lawyers, accountants or auditors
  • public authorities, regulators, courts or law-enforcement bodies where disclosure is legally required

Fair applies data minimisation when sharing information. A hotel, for example, generally does not need your hair-loss photographs or medical history.

9. International data transfers

Fair serves international patients and may use service providers whose systems or support operations are located outside Türkiye.

If personal data are transferred outside Türkiye, Fair uses a transfer method permitted by the Turkish Personal Data Protection Law (KVKK) and the applicable cross-border transfer rules.

Where GDPR or UK GDPR applies, transfers outside the relevant protected area must also rely on an appropriate lawful mechanism, such as an adequacy decision, approved contractual safeguards or another permitted transfer basis where required.

10. WhatsApp and other communication platforms

If you contact Fair through WhatsApp or another third-party communication platform, that provider may process information under its own privacy terms and technical infrastructure.

Do not send more medical information than necessary. If Fair introduces a dedicated secure patient portal or other clinical channel, patients will be directed to the appropriate system for sensitive information.

Fair remains responsible for using approved business accounts and internal access controls on its side, but it cannot rewrite the privacy practices of an independent platform provider.

11. Cookies, analytics and advertising

Fair may use cookies or similar technologies for website functionality, security, analytics and marketing.

Strictly necessary technologies may operate without optional consent where legally permitted. Non-essential analytics or advertising technologies are intended to be activated only in accordance with your consent choices where consent is required.

For details about the cookies and technologies used on the live website, see our Cookie Policy.

12. Marketing communications

Fair may send marketing messages only where a lawful basis exists and any required permission has been obtained.

You can opt out of marketing messages using the unsubscribe method provided or by contacting Fair.

Opting out of marketing does not stop necessary service, booking, treatment or follow-up communications related to an existing patient relationship.

13. Before/after photos, reviews and social media

Treatment photos submitted for assessment or created during care are not automatically marketing material.

If Fair wants to use an identifiable patient’s photographs, video, testimonial or review content for marketing, Fair asks for separate, specific permission that is not bundled into treatment consent.

Marketing permission is voluntary and is not a condition of receiving treatment.

You can ask Fair to stop future use of your marketing material at any time, subject to applicable law and the practical limits of material already lawfully published or distributed.

Treatment consent ≠ marketing consent.

14. How long do we keep personal data?

Fair does not keep personal data longer than necessary for the purpose for which it was collected, unless a longer period is required or permitted by law, medical-record rules, accounting/tax rules, legal claims or another legitimate requirement.

Data categoryRetention
General enquiriesFor as long as needed to answer your enquiry and any related follow-up, then deleted or anonymised.
Free Hair Analysis / assessment photosFor as long as needed for your assessment and treatment planning. You can ask us to delete them at any time.
Patient coordination / booking recordsFor the duration of the patient relationship and for the period required by applicable law.
Clinical records held by the medical providerKept by the treating hospital / provider under its own legal retention obligations and privacy notice.
Payment / invoice recordsFor the period required by Turkish tax and commercial law.
Marketing consent recordsWhile your consent is active and for as long as needed to demonstrate it.
Website security logsFor limited periods needed to keep the website secure.

15. How do we protect personal data?

Fair uses appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Measures may include access controls, staff permissions, secure credentials, device and account security, protected storage, backups, vendor controls and staff confidentiality procedures, depending on the system and sensitivity of the data.

No website, messaging platform or storage system can be guaranteed to be 100% secure.

16. Automated decision-making

Fair does not make treatment-suitability decisions solely by an automated graft calculator or other automated system.

The Free Hair Analysis is reviewed by people. If Fair later introduces automated profiling or decision-making that has legal or similarly significant effects, this Policy will be updated before use.

17. Your privacy rights

Your rights depend on the law that applies to your personal data.

Under Turkish KVKK

You may have rights including asking whether your personal data are processed, requesting information about processing, learning the purpose and recipients of processing, requesting correction of incomplete or inaccurate data, requesting deletion or destruction where legal conditions are met, and exercising other rights provided by applicable law.

Where GDPR / UK GDPR applies

You may also have rights such as access, rectification, erasure, restriction, objection, data portability, withdrawal of consent and rights relating to certain automated decisions, subject to the conditions and exceptions in applicable law.

To exercise a privacy right, contact Fair using the privacy contact below. Fair may need to verify your identity before acting on a request.

You may also have a right to complain to the competent data-protection authority under applicable law.

18. Children and minors

Fair’s website is designed for adults seeking information about elective hair-restoration services.

Fair does not knowingly collect health data from a child through ordinary website flows without an appropriate legal basis and, where required, parent or guardian involvement.

If a minor’s case is ever considered for a legitimate medical reason, it is handled through an appropriate medical and legal process rather than the standard booking flow.

19. Third-party websites and services

The Fair website may link to external websites or services. Their privacy practices are controlled by those third parties, not by this Privacy Policy.

Please review the privacy information of third-party platforms you choose to use.

20. Changes to this Privacy Policy

Fair may update this Privacy Policy when its services, technology, providers or legal obligations change.

The latest version always shows a clear “Last updated” date. Material changes will be communicated where required by law.

21. Contact Fair about privacy

Questions or requests about this Privacy Policy or Fair’s use of personal data can be sent to:

  • FAIR HAIR CLINIC ULUSLARARASI SAĞLIK TURİZMİ ORGANİZASYON LİMİTED ŞİRKETİ
  • Istanbul, Türkiye
  • Privacy email: info@fairhairclinic.com

General treatment questions can be sent through our Contact page or the Free Hair Analysis.