Privacy Policy

1. Who we are

This website is operated by Op. Dr. Yasin Kürşad Varsak, a facial plastic surgeon practising in Türkiye. For the purposes of Turkish data protection law (KVKK No. 6698), the data controller is:

DATA CONTROLLER

[KAYITLI TİCARİ UNVAN]

ADDRESS

Osman Yılmaz Mah. İstanbul Cad., Cadde İstanbul Plaza No: 28/17, Gebze 41400, Kocaeli, Türkiye

EMAIL

[email protected]

TELEPHONE / WHATSAPP

+90 546 527 36 38

VERBİS REGISTRATION

[VERBİS NUMARASI — kayıt yükümlülüğü varsa]

This policy explains what we do with the information you give us when you enquire about surgery, browse this website, or become a patient.

2. What information we collect

Information you give us

• Your name, email address, telephone or WhatsApp number and country
• The procedure you are enquiring about and your preferred timeframe
• Photographs and any medical imaging you choose to upload
• Anything else you write to us in the enquiry form, by email or over WhatsApp

Information collected automatically

• IP address, browser type, device type and approximate location
• Pages viewed, time on page and how you arrived at this website
• Advertising identifiers where you arrived from a Meta or Google advertisement

3. Photographs, scans and health information

These materials are seen only by Dr. Varsak and the clinical and coordination staff who need them to assess your case. They are never published, never used in marketing, and never shown to anyone else unless you give us separate written consent for that specific use. Consenting to an assessment is not consent to publication, and you may withdraw either consent at any time.

Please note that we are a healthcare provider established in Türkiye. We are not a HIPAA covered entity under United States law, and this policy should not be read as a HIPAA notice of privacy practices.

4. Why we use your information

• To assess your case and tell you which technique is appropriate for your anatomy
• To prepare a written quotation and answer your questions
• To plan and deliver treatment, including hospital admission, anaesthesia and follow-up
• To arrange your stay — accommodation, transfers and the mandatory complication insurance
• To meet legal obligations, including medical record-keeping requirements under Turkish law
• To measure and improve our advertising, where you have consented to marketing cookies

We do not use your enquiry information to send marketing messages unless you have separately asked us to. We do not sell your information.

5. Who we share it with

• The treating hospital — Anadolu Medical Center, where surgery is performed
• Insurers, for the complication policy required by the Turkish Ministry of Health
• Accommodation and transfer providers, limited to the details needed to book
• Our CRM and messaging platforms, which store enquiries and correspondence
• Analytics and advertising platforms, where you have consented to those cookies
• Professional advisers or authorities, where we are legally required to disclose

Providers act on our instructions under written agreements and may not use your information for their own purposes.

6. Where your information is processed

Your information is processed in Türkiye, and by service providers that may store data in the European Union or the United States. If you are contacting us from outside Türkiye, submitting the enquiry form means your information will be transferred to Türkiye for assessment and, if you proceed, for treatment. Türkiye has its own data protection framework (KVKK) but has not been the subject of an adequacy decision by every jurisdiction. Where a transfer requires your explicit consent under KVKK Article 9, that consent is requested on the enquiry form.

7. How long we keep it

ENQUIRIES THAT DO NOT PROCEED

Up to [24] months from your last contact with us, then deleted

PATIENT MEDICAL RECORDS

Retained for the period required by Turkish healthcare legislation

ACCOUNTING RECORDS

10 years, as required by Turkish commercial law

WEBSITE ANALYTICS

Up to 14 months, or as set in the relevant platform

8. How we protect it

This website uses TLS encryption. Access to enquiries, photographs and medical records is restricted to staff who need it, protected by individual accounts and multi-factor authentication where the platform supports it. Staff are bound by confidentiality obligations. No system can be guaranteed completely secure, but we take these measures seriously and review them regularly.

9. Your rights

Under KVKK Article 11 and comparable laws, you may ask us to:

• Confirm whether we hold information about you, and give you a copy
• Correct information that is inaccurate or incomplete
• Delete information we no longer have a lawful reason to keep
• Restrict or object to certain uses of your information
• Withdraw a consent you previously gave, at any time
• Tell you who your information has been shared with

Withdrawing consent does not affect anything we did lawfully before you withdrew it, and we may still need to keep medical records where the law requires it. Write to us at [email protected] and we will respond within 30 days. If you are not satisfied with our response, you may complain to the Turkish Personal Data Protection Authority (KVKK).

10. Additional rights for United States residents

If you live in California, Colorado, Connecticut, Virginia or another state with a comprehensive privacy law, you have the right to know what personal information we collect, to request a copy, to request correction or deletion, and not to be discriminated against for exercising those rights.

We do not sell personal information, and we do not share it for cross-context behavioural advertising in the sense those terms are used in the California Consumer Privacy Act. Health information you send us is treated as sensitive personal information and is used only for the purposes described in section 4.

To exercise any of these rights, contact us at [email protected]. You may use an authorised agent, and we may need to verify your identity before acting on the request.

11. Cookies and tracking

We use cookies that are necessary for the website to function, and — with your consent — analytics and advertising cookies, including the Meta pixel and Google Ads and Analytics tags. These help us understand which advertisements bring people to this page.

You can accept or reject non-essential cookies through the banner shown on your first visit, change your choice at any time via [ÇEREZ AYARLARI LİNKİ], and block or delete cookies in your browser settings. Rejecting non-essential cookies does not affect your ability to use the enquiry form.

12. Children

This website and the procedures described on it are intended for adults. We do not knowingly collect information from anyone under 18. If you believe a minor has sent us information, contact us and we will delete it.

13. Changes to this policy

We may update this policy as our practices or the law change. The date at the top of the page shows when it was last revised. Material changes will be highlighted on this page.