PRIVACY POLICY

WHO IS RESPONSIBLE FOR YOUR DATA

The data controller is Dr. Safa Manav Clinic (Plastic, Reconstructive and Aesthetic Surgery), Harbiye, Marmara Apartmanı, Vali Konağı Cd. No:16/1, 34371 Şişli / Istanbul, Türkiye.

For any privacy question, or to exercise the rights described below, contact info@drsafamanav.com or write to the clinic address above. This is also the contact point for data protection matters under the GDPR, the UK GDPR and Turkish Law No. 6698 (KVKK).

This website and the services described on it are intended for adults aged 18 or over. We do not knowingly collect information from minors. If you believe a minor has submitted information, contact us and we will delete it.

INFORMATION WE COLLECT

Enquiry data: when you submit the assessment form we collect your name, email address, telephone or WhatsApp number, and the free-text description of your request. The form does not ask for detailed health information.

Health-related data: if you choose to continue with a preliminary assessment, the coordinator may ask you to send medical information or photographs (medical conditions, medications, previous surgery, smoking status). Providing this is voluntary and always at your choice.

Technical data: our website records limited technical information such as browser type, device type, approximate region and pages viewed, to keep the site working correctly and measure general usage. Non-essential cookies are described in our Cookie Policy.

WHY WE USE IT AND THE LEGAL BASIS

Responding to your enquiry and coordinating a possible treatment: GDPR Article 6(1)(b) (steps taken at your request prior to a contract) and Article 6(1)(f) (our legitimate interest in answering enquiries).

Reviewing medical information and photographs to prepare a preliminary assessment, and providing treatment and follow-up care: GDPR Article 9(2)(a) — your explicit consent — and, where treatment proceeds, Article 9(2)(h) (provision of health care by professionals bound by medical confidentiality).

Keeping the site secure and functional, and meeting medical record-keeping and accounting obligations: GDPR Article 6(1)(f) and Article 6(1)(c). We do not use your enquiry or medical data for automated decision-making or profiling.

INTERNATIONAL DATA TRANSFERS

The clinic is located in the Republic of Türkiye, and information you submit is transferred to and processed in Türkiye. Türkiye is not currently covered by a European Commission adequacy decision.

Where you submit an enquiry or health information from the EEA or the United Kingdom, that transfer is made on the basis of your explicit consent to the transfer under GDPR Article 49(1)(a), and, where treatment is arranged, because the transfer is necessary to perform a contract concluded in your interest under Article 49(1)(b).

We apply organisational and technical safeguards to transferred data, including access limited to the clinical and coordination staff involved in your care, professional medical confidentiality obligations under Turkish law, and encrypted transmission and storage of enquiry and medical records.

SHARING AND RECIPIENTS

Information may be shared with the hospital, anesthesiology team, laboratory, accommodation provider or transfer provider involved in your treatment, and only to the extent required to deliver that treatment safely. These recipients are bound by confidentiality obligations.

Service providers that host this website, deliver our email, or measure general website usage process limited data on our instructions. Patient photographs are published only with separate, specific written consent, which you may withdraw at any time.

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising or targeted advertising as those terms are defined under US state privacy laws.

ADVERTISING MEASUREMENT

If you agree to it in the cookie notice, this website uses the Microsoft Advertising UET tag from Microsoft Corporation. It records which pages you view, whether you submit the enquiry form, and which advertisement or search brought you here, so we can measure and improve our advertising. Microsoft processes this data as our service provider, and it may be processed in the United States and other countries where Microsoft operates.

No medical information, name, email address or telephone number is sent to Microsoft, and we do not upload customer lists for advertising matching. The legal basis is your consent (GDPR Article 6(1)(a)); visitors in the United Kingdom, the European Economic Area, Switzerland and Türkiye are asked before any advertising cookie is set. You can withdraw consent at any time using the Cookie settings link in the footer, and withdrawal is as easy as giving consent.

RETENTION

Patient records are retained in line with Turkish medical record-keeping requirements, which generally require health records to be kept for a minimum period after the last treatment. Enquiries that do not lead to treatment are deleted within 12 months of our last contact with you, unless you ask us to delete them sooner.

Technical website data is kept for a short period only, as described in our Cookie Policy.

YOUR RIGHTS (EEA, UK AND TÜRKIYE)

If you are in the EEA or the UK, you have the right to access your data, to have it corrected or erased, to restrict or object to its processing, to data portability, and to withdraw consent at any time without affecting processing already carried out. Similar rights, including the right to learn whether your data is processed and to request its correction or deletion, apply under Turkish Law No. 6698 (KVKK).

To exercise any of these rights, email info@drsafamanav.com. We respond within one month, and will tell you if we need longer for a complex request. We may ask for information to confirm your identity before acting.

You also have the right to complain to a supervisory authority: your national data protection authority in the EEA, the Information Commissioner's Office in the UK (ico.org.uk), or the Turkish Personal Data Protection Authority (KVKK).

UNITED STATES PRIVACY NOTICE

This section applies to residents of US states with comprehensive privacy laws, including California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah and Texas. Notice at collection: we collect identifiers (name, email, phone), internet activity information, and, if you choose to provide it, health information, which is treated as sensitive personal information. It is collected for the purposes described above and retained for the periods stated above.

You have the right to know and access the personal information collected about you, to request its deletion, to request correction of inaccurate information, to limit the use of sensitive personal information, to opt out of sale or sharing, and not to be discriminated against for exercising these rights. We do not sell or share personal information, and we use sensitive personal information only to respond to and deliver the services you request.

To make a request, email info@drsafamanav.com with the subject line "US privacy request". You may use an authorised agent; we will verify the request using the contact details we hold. We will acknowledge within 10 business days and respond within 45 days, extendable once where permitted.

CONSENT, WITHDRAWAL AND SECURITY

Consent given when you submit the assessment form covers contact by email, telephone or WhatsApp, processing of the information you provide, and transfer of that information to the clinic in Türkiye. Each consent is separate and voluntary, and you may withdraw any of them at any time by emailing info@drsafamanav.com or replying STOP to a message.

We use encrypted connections, restricted access and confidentiality obligations to protect your information. No transmission over the internet can be guaranteed to be completely secure, so please do not send medical photographs or documents through unsecured channels unless the coordinator has confirmed how to do so safely.

CHANGES TO THIS POLICY

We may update this policy to reflect changes in our services or in applicable law. The date at the top of this page shows when it was last revised. Material changes affecting how we use your information will be notified to you by email where we hold your contact details.