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Privacy Notice (KVKK Disclosure)
Pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK), we would like to inform you, in our capacity as data controller, about how we process your personal data.
1. Identity of the Data Controller
Your personal data is processed by the business whose identity and contact details are set out below, acting in the capacity of data controller.
2. Personal Data We Process
If you contact us through our website, the following data is processed:
- Identity data: first name and surname.
- Contact data: telephone number and, where provided, e-mail address.
- Content of your enquiry: the treatment you are interested in (hair, beard or eyebrow transplant) and your free-text message.
- Transaction security data: the page address from which the enquiry was submitted, your language preference, and the date and time of the enquiry.
- Marketing data: browsing data collected through cookies, only where you have given your explicit consent.
IMPORTANT: Information about the treatment you are interested in and your free-text message may constitute SPECIAL CATEGORY PERSONAL DATA (health data) within the meaning of Article 6 of the KVKK and Article 9 of the GDPR. For this reason, such data is processed solely on the basis of YOUR EXPLICIT CONSENT. Please do not share any health information in the form that is not strictly necessary.
3. Purposes of Processing
- To respond to your enquiry and schedule a preliminary consultation.
- To inform you about treatment options that may be suitable for you.
- To measure and improve the quality of our services.
- Where you have given your explicit consent, to carry out promotional activities relevant to your interests.
- To fulfil our obligations arising from applicable legislation.
4. Legal Grounds
| Type of data | Legal ground (KVKK) |
|---|---|
| Name, telephone, e-mail | Art. 5(2)(c) — directly related to the conclusion or performance of a contract; Art. 5(2)(f) — legitimate interest (equivalent to GDPR Art. 6(1)(b) and 6(1)(f)) |
| Health-related enquiry information and free-text message | Art. 6(2) — EXPLICIT CONSENT (equivalent to GDPR Art. 9(2)(a)) |
| Strictly necessary cookies | Art. 5(2)(f) — legitimate interest (operation of the website) |
| Analytics and advertising cookies | Art. 5(1) — EXPLICIT CONSENT |
5. Transfer of Personal Data
Your personal data is not shared with third parties except in the following cases:
- Our hosting and infrastructure service providers — for the purpose of storing the data.
- Where you have given your explicit consent, analytics and advertising service providers (Google, Meta). The servers of these providers may be located abroad; in that case the data is transferred abroad within the scope of Article 9 of the KVKK, and such transfer is based on your explicit consent.
- Legally authorised public authorities and institutions — upon request and as required by law.
If you do not give cookie consent, no data whatsoever is transferred to Google or Meta.
6. Retention Period
- Contact form enquiries: a maximum of 2 years from the conclusion of your enquiry.
- Cookie consent record: 6 months (consent is requested again once this period expires).
- Where legislation prescribes a longer retention period, that period applies.
At the end of these periods, your data is deleted, destroyed or anonymised.
7. Your Rights under the KVKK
Pursuant to Article 11 of the KVKK, you have the following rights, which you may exercise by applying to the data controller:
- To learn whether your personal data is being processed.
- To request information if your data has been processed.
- To learn the purpose of processing and whether the data is used in accordance with that purpose.
- To know the third parties, in Türkiye or abroad, to whom your data has been transferred.
- To request rectification if your data has been processed incompletely or inaccurately.
- To request erasure or destruction of your data under the conditions set out in Article 7 of the KVKK.
- To request that rectification, erasure and destruction operations be notified to the third parties to whom the data has been transferred.
- To object to any adverse outcome for you that arises from analysis carried out exclusively by automated means.
- To claim compensation if you suffer damage as a result of unlawful processing.
- To withdraw the explicit consent you have given at any time.
8. How to Submit a Request
You may submit requests relating to your rights, together with information verifying your identity, through the contact channels set out below. Your request will be concluded within 30 days at the latest.
Nirvana Hair
Çınar, Fatih Cd. 1/23 Kat: 7, Kapı No:709, 35090 Bornova/İzmir (Çiçek plaza)