Legal
Privacy Policy and Personal Data Protection Notice
How Pure Line Clinic handles personal information
This Privacy Policy and Personal Data Protection Notice explains how Pure Group Saglik Turizm LTD, operating as Pure Line Clinic, collects, processes, stores, protects, transfers and deletes personal data shared through our website, consultation forms, WhatsApp, email, telephone calls, social media messages, in-person consultations and other communication channels.
Pure Line Clinic processes personal data in accordance with applicable data protection laws, including the Turkish Personal Data Protection Law No. 6698, known as KVKK, and, where applicable, the General Data Protection Regulation, known as GDPR.
For the purposes of KVKK, Pure Group Saglik Turizm LTD, operating as Pure Line Clinic, acts as the data controller.
1. Data Controller Information
- Data Controller: Pure Group Saglik Turizm LTD, operating as Pure Line Clinic
- Address: Bagdat Caddesi No:19/12 Manolya Apartment, Kadikoy, Istanbul, Turkiye
- Telephone: +90 544 575 55 90
- Email: info@purelineclinic.com
- Website: purelineclinic.com
2. Personal Data We May Process
Depending on how you contact us and which services you request, we may process the following categories of personal data:
Identity Information
Name, surname, age, gender, nationality, passport information or identity information where necessary for health tourism, appointment, travel or legal processes.
Contact Information
Phone number, email address, country of residence, WhatsApp number, address, social media account information and communication preferences.
Health and Medical Information
Medical history, current health concerns, medications, allergies, previous procedures, surgical history, hair loss history, treatment expectations, donor area information, photographs, videos and other health-related details you voluntarily share with us for consultation, assessment, planning or follow-up.
Visual and Audio Data
Photographs, videos, consultation images, before-and-after images, online consultation records, and, where applicable, call or video meeting records.
Transaction and Service Information
Appointment details, consultation notes, treatment planning records, patient communication records, hotel and transfer organisation details, payment-related information, invoice information and service history.
Digital and Website Usage Data
IP address, browser type, device information, cookie data, form submission records, website usage data, analytics data and similar technical information.
Legal and Compliance Data
Records required for legal obligations, dispute management, invoice/tax processes, official correspondence and requests from authorised public institutions.
3. Purposes of Processing Personal Data
Your personal data may be processed for the following purposes:
- Responding to your consultation requests
- Evaluating your suitability for hair transplantation or other medical aesthetic services
- Planning medical consultations, treatment processes and patient follow-up
- Reviewing photographs and medical information shared by you
- Communicating with you through WhatsApp, email, telephone, website forms or social media
- Organising appointment, accommodation, transfer and health tourism processes
- Preparing treatment plans, price offers and service information
- Managing patient relationship processes
- Fulfilling legal, tax, accounting and regulatory obligations
- Ensuring patient safety and treatment continuity
- Managing complaints, requests and disputes
- Improving our services, website and communication channels
- Conducting internal operational, administrative and quality-control processes
- Protecting the legal rights of Pure Line Clinic, patients and third parties
4. Legal Grounds for Processing Personal Data
Your personal data may be processed based on one or more of the following legal grounds under KVKK and applicable legislation:
- Your explicit consent
- The necessity of processing for the establishment or performance of a contract
- The necessity of processing for compliance with legal obligations
- The necessity of processing for the establishment, exercise or protection of a legal right
- The legitimate interests of the data controller, provided that such processing does not harm your fundamental rights and freedoms
- Processing being necessary for medical assessment, diagnosis, treatment planning, health tourism services or patient relationship management, where permitted by law and/or based on your explicit consent
Health data, medical photographs and other sensitive personal data are processed only where legally permitted and, where required, based on your explicit consent.
5. Processing of Sensitive Personal Data
Some data you share with us may qualify as sensitive personal data under KVKK. This may include health information, medical photographs, treatment history, medication use, allergy information, surgical history, biometric-like visual data and other medical details.
Pure Line Clinic processes sensitive personal data only for limited and specific purposes, including:
- Medical assessment and consultation
- Treatment planning
- Risk evaluation
- Patient follow-up
- International health tourism service planning
- Patient relationship management
- Compliance with legal obligations
- Protection of patient safety and medical service quality
Sensitive personal data is processed with appropriate technical and organisational measures and, where required, only after obtaining your explicit consent.
6. How We Collect Personal Data
Your personal data may be collected through:
- Website contact forms
- WhatsApp messages
- Email communication
- Telephone calls
- Social media messages
- Online consultation forms
- In-person consultation forms
- Photographs, videos and documents shared by you
- Clinic automation systems
- Patient relationship management systems
- Hotel, transfer or health tourism coordination processes
- Cookies and similar website technologies
Personal data may be collected electronically, physically, verbally or through automated/non-automated methods.
7. Transfer of Personal Data
Your personal data may be shared only where necessary and limited to the purpose of processing. Your data may be transferred to the following parties:
- Authorised employees and consultants of Pure Line Clinic
- Doctors, healthcare professionals and medical team members involved in your consultation or treatment planning
- Health tourism service providers
- Hotel, transfer and travel coordination partners, where necessary
- Clinic automation and patient management software providers
- IT, hosting, cloud, email, data storage and technical service providers
- Accounting, tax, legal and financial advisors
- Payment service providers and banks, where applicable
- Public institutions, courts, enforcement offices and authorised legal authorities, where legally required
- Business partners and service providers involved in jointly conducted operational activities
Personal data is not sold, rented or disclosed to unrelated third parties for commercial purposes.
8. International Transfer of Personal Data
As Pure Line Clinic provides international health tourism services, your personal data may be transferred abroad in limited circumstances, especially where communication, cloud storage, clinic automation, email, WhatsApp, hosting, technical support, travel coordination or international patient management systems involve service providers located outside Turkiye.
International transfers are carried out only where legally permitted, based on applicable legal grounds and, where required, your explicit consent.
If sensitive personal data such as medical photographs or health information is transferred abroad, such transfer will be limited to the necessary purpose and carried out with appropriate safeguards.
9. Data Retention Period
Your personal data is retained only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law. Retention periods may vary depending on the type of data:
- Consultation and communication records may be retained for patient relationship management and follow-up purposes
- Medical assessment and treatment planning records may be retained for patient safety, continuity of care and legal compliance
- Invoice, accounting and tax records are retained for the legally required period
- Website and cookie data may be retained for shorter technical and analytics periods
- Complaint, dispute and legal correspondence records may be retained until the relevant limitation periods expire
When the retention period expires, personal data is deleted, destroyed or anonymised in accordance with applicable law.
10. Data Security
Pure Line Clinic applies reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction. These measures may include:
- Access limitation
- Secure storage systems
- Password-protected digital systems
- Internal confidentiality rules
- Staff awareness and authorisation controls
- Limited access to patient photographs and health data
- Secure communication and data management practices
- Regular review of data processing activities
However, no digital transmission or storage system is completely secure. Therefore, while we take appropriate precautions, we cannot guarantee absolute security of data transmitted over the internet.
11. Your Rights Under KVKK
As a data subject, you have the right to apply to Pure Line Clinic and request the following:
- To learn whether your personal data is being processed
- To request information if your personal data has been processed
- To learn the purpose of processing and whether your data is used in accordance with that purpose
- To know the third parties to whom your personal data has been transferred domestically or abroad
- To request correction of incomplete or inaccurate personal data
- To request deletion or destruction of your personal data where legally possible
- To request notification of correction, deletion or destruction to third parties to whom your data has been transferred
- To object to any unfavourable result arising from the analysis of your data exclusively through automated systems
- To request compensation if you suffer damage due to unlawful processing of your personal data
You may submit your requests by contacting us at info@purelineclinic.com or by writing to Bagdat Caddesi No:19/12 Manolya Apartment, Kadikoy, Istanbul, Turkiye. Requests must include sufficient information to verify your identity. Pure Line Clinic will respond to your request within the period required by applicable law.
12. Withdrawal of Consent
Where your personal data is processed based on your explicit consent, you may withdraw your consent at any time by contacting us in writing.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. However, if you withdraw consent for the processing of data necessary for consultation, medical assessment, treatment planning or follow-up, Pure Line Clinic may not be able to continue providing certain services.
13. Children's Data
Pure Line Clinic does not knowingly collect, process or store personal data of individuals under the age of 18 without the consent of a parent or legal guardian.
If we become aware that personal data of a child has been shared with us without proper consent, we may use such information only to inform the individual that parental or guardian consent is required, and may delete the relevant data where appropriate.
15. Links to Other Websites
Our website may contain links to third-party websites, platforms or services. Pure Line Clinic is not responsible for the privacy practices, content or security of websites that are not owned or controlled by us. When you visit a third-party website, you should review that website's own privacy policy.
16. Changes to This Policy
Pure Line Clinic may update this Privacy Policy and Personal Data Protection Notice from time to time due to legal, operational or technical changes. The updated version will be published on our website. Where required by law, we may also notify you through appropriate communication channels.
17. Contact
For any questions, requests or concerns regarding this Privacy Policy or the processing of your personal data, you may contact us at:
- Company: Pure Group Saglik Turizm LTD, operating as Pure Line Clinic
- Address: Bagdat Caddesi No:19/12 Manolya Apartment, Kadikoy, Istanbul, Turkiye
- Telephone: +90 544 575 55 90
- Email: info@purelineclinic.com