Privacy Policy

1. Introduction

The Health Store Turkey ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website (www.thehealthstoreturkey.com) and our services.

By using our website or providing us with your personal information, you consent to the practices described in this policy.

2. Information We Collect

We may collect the following types of personal information:

Information you provide directly:

• Name, email address, phone number (via contact forms, WhatsApp, or phone)
• Medical history and health information (during consultations)
• Payment information (processed securely by third-party providers)

Information collected automatically:

• IP address, browser type, device information
• Pages visited, time spent on pages, referring URLs
• Cookies and similar tracking technologies (see our Cookie Policy)

3. How We Use Your Information

We use your personal information to:

• Respond to enquiries and provide consultations
• Arrange and manage your treatment plan
• Send appointment reminders and aftercare communications
• Improve our website and services
• Send marketing communications (only with your consent)
• Comply with legal obligations

4. Legal Basis for Processing

We process your personal information based on:

• Consent, when you submit a form or opt in to communications
• Contract, when necessary to provide our services
• Legitimate interests, to improve our services and communicate with patients
• Legal obligation, to comply with applicable laws

5. Special Category Health Data

Some of the personal data we process is classified as "special category data" under UK GDPR Article 9. This includes your medical history, health conditions, treatment plans, surgical records, and any before-and-after photographs.

We process this data on the following legal bases:

• Article 9(2)(a), Explicit consent: You provide explicit consent when you share your medical information with us during your consultation and booking process
• Article 9(2)(h), Health and social care: Processing is necessary for the provision of health care or treatment, carried out by or under the responsibility of a health professional

You can withdraw your consent to the processing of your health data at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

6. Data Sharing

We may share your personal information with:

• Our partner hospitals and medical teams in Turkey (to arrange your treatment)
• HubSpot (our CRM platform, for managing patient communications)
• Google Analytics (anonymised website usage data)
• MailChimp (if you subscribe to our newsletter)
• SuperChat (for messaging)

We do not sell your personal information to third parties.

7. International Data Transfers

To provide our services, your personal data, including health data, is transferred from the UK to Turkey, where our partner hospitals and surgical teams are based. Turkey does not currently hold a UK adequacy decision for data protection purposes.

To protect your data during these transfers, we use Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office, along with additional safeguards where appropriate.

Our Turkish partner hospitals also comply with Turkey's Personal Data Protection Law (KVKK, Kişisel Verilerin Korunması Kanunu), which provides additional protections for your data within Turkey.

8. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected:

• Medical records and treatment data: 10 years from the date of your last treatment, in line with medical record-keeping best practice
• Marketing and communication preferences: Until you withdraw consent or unsubscribe
• Website analytics data: 26 months (Google Analytics default retention period)
• Enquiry and contact form data: 3 years from your last interaction with us
• Financial and payment records: 7 years, as required by UK tax and accounting regulations

After these periods, your data is securely deleted or anonymised.

9. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

• Right of access: You can request a copy of the personal data we hold about you
• Right to rectification: You can ask us to correct inaccurate or incomplete data
• Right to erasure: You can ask us to delete your personal data in certain circumstances
• Right to restrict processing: You can ask us to limit how we use your data
• Right to data portability: You can request your data in a structured, machine-readable format
• Right to object: You can object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, contact us at info@thehealthstoreturkey.com. We will respond to your request within one calendar month.

If you are not satisfied with how we handle your request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

10. Before-and-After Photographs

If before-and-after photographs are taken as part of your treatment, we will obtain your explicit, written consent before using them for any purpose beyond your medical record. Consent for use on our website and consent for use on social media are treated as separate permissions, you can agree to one without the other.

All photographs are anonymised where possible, and metadata (location data, timestamps) is stripped before any publication. You can withdraw your consent for photograph use at any time, and we will remove any published images promptly.

11. Cookies

We use cookies to improve your experience on our website. For full details, please see our Cookie Policy.

12. Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last updated.

14. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us:

• Email: info@thehealthstoreturkey.com
• Phone: +44 7733 596821
• WhatsApp: +44 7733 596821