TURKEY LASER GUIDE PRIVACY POLICY
Governing Law: England and Wales
This Privacy Policy explains how Turkey Laser Guide collects, uses, stores, and protects your personal data when you use this Website or interact with us. We are committed to protecting your privacy and handling your data responsibly in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Please read this policy carefully. By using this Website you acknowledge that you have read and understood how we handle your personal data.
PART 1 — WHO WE ARE
1.1 Data Controller
Turkey Laser Guide is the data controller responsible for your personal data. Turkey Laser Guide is a trading name of a company registered in England and Wales.
1.2 Contact
For all data protection enquiries please contact us via the contact form on this Website.
1.3 Data Protection Officer
All data protection matters are handled directly by Turkey Laser Guide’s management.
PART 2 — DATA WE COLLECT
2.1 Information You Provide Directly
We collect personal data that you voluntarily provide to us including:
(a) Identity data — your full name, date of birth, and nationality; (b) Contact data — your email address, telephone number, and WhatsApp number; (c) Health data — medical history, current medications, existing conditions, previous eye treatments, and procedure requirements that you voluntarily share with us. This constitutes special category data under UK GDPR and is handled with the highest level of protection; (d) Communications data — records of all correspondence between you and Turkey Laser Guide including enquiry forms, emails, and WhatsApp messages.
2.2 Information Collected Automatically
When you visit this Website we may automatically collect:
(a) Technical data — your IP address, browser type and version, device type, operating system, and time zone; (b) Usage data — pages visited, time spent on pages, links clicked, and referring URLs; (c) Cookie data — as described in our Cookie Policy.
2.3 Information We Do Not Collect
Turkey Laser Guide does not collect or store payment card details. All payment data is handled exclusively by Stripe in accordance with PCI DSS standards. Please refer to Stripe’s privacy policy at stripe.com/privacy for information on how Stripe handles your payment data.
PART 3 — HOW WE USE YOUR DATA
3.1 Purposes of Processing
We use your personal data for the following purposes:
(a) To respond to your enquiries and provide general information about laser eye surgery options in Turkey; (b) To facilitate a connection between you and an independent Medical Provider at your request; (c) To facilitate the reservation of a Surgical Date where a Surgical Reservation Fee has been paid; (d) To communicate with you regarding your enquiry and any arrangements made; (e) To share relevant information with a Medical Provider at your explicit request and with your consent; (f) To process payments via Stripe; (g) To improve our Website and the quality of information we provide; (h) To comply with our legal obligations; (i) To defend any legal claims brought against us.
3.2 Health Data
Health data is special category data under UK GDPR. We process your health data only where you have provided explicit consent by voluntarily sharing it with us and requesting a connection to a Medical Provider. Health data shared with us will only be passed to a Medical Provider at your explicit request and for the sole purpose of facilitating your medical enquiry.
PART 4 — LEGAL BASIS FOR PROCESSING
4.1 We process your personal data on the following legal bases:
(a) Consent — where you have provided explicit consent, including for the processing of special category health data. You may withdraw consent at any time by contacting us via the contact form on this Website. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal; (b) Contract — where processing is necessary to facilitate a Surgical Date reservation or other service you have requested; (c) Legitimate interests — for Website analytics, service improvement, and the defence of legal claims, where such interests are not overridden by your rights and freedoms; (d) Legal obligation — where processing is required to comply with applicable law.
PART 5 — SHARING YOUR DATA
5.1 Medical Providers
Where you request a connection to a Medical Provider, we will share relevant personal and health data with that Medical Provider solely for the purpose of facilitating your medical enquiry. By requesting a connection you explicitly consent to this transfer.
5.2 Payment Processing
Payment data is shared with Stripe solely for the purpose of processing your Surgical Reservation Fee. Turkey Laser Guide does not have access to your full payment card details at any time.
5.3 Legal and Regulatory Disclosure
We may disclose your personal data where required to do so by law, regulation, or court order, or where necessary to protect our legal rights or defend legal claims.
Form Processing
Where you submit an enquiry or assessment form on this Website, your data is processed by an independent third-party form processing provider. This provider acts as a data processor on our behalf and processes your data solely for the purpose of transmitting your form submission to us. Their privacy policy is available on request
Appointment Scheduling
Where you use a scheduling or booking tool on this Website to arrange an appointment or call, your data is processed by an independent third-party scheduling provider. This provider acts as a data processor on our behalf and processes your data solely for the purpose of facilitating your appointment booking. Their privacy policy is available on request.
5.4 No Sale of Data
Turkey Laser Guide does not sell, rent, or otherwise commercially exploit your personal data to any third party under any circumstances.
5.5 No Marketing Sharing
Turkey Laser Guide does not share your personal data with any third party for marketing purposes.
PART 6 — INTERNATIONAL DATA TRANSFERS
6.1 Transfer to Turkey
Where you request a connection to a Medical Provider in Turkey, your personal and health data will necessarily be transferred to that Medical Provider in Turkey. Turkey is not currently recognised by the UK as providing an equivalent level of data protection to the UK GDPR.
6.2 Safeguards
Where we transfer personal data to Turkey we rely on your explicit consent as the transfer mechanism under UK GDPR Article 49(1)(a). By requesting a connection to a Medical Provider in Turkey you explicitly consent to this international transfer of your personal data.
6.3 Risks
You should be aware that data transferred to Turkey will be subject to Turkish data protection law which may differ from UK GDPR protections. We take reasonable steps to ensure that any Medical Provider receiving your data handles it responsibly and securely.
PART 7 — DATA RETENTION
7.1 General Retention Period
We retain your personal data for a period of seven years following your last interaction with us or the completion of any arrangement facilitated through Turkey Laser Guide, whichever is later. This retention period reflects our legal obligations and the potential for long-term medical implications arising from procedures.
7.2 Health Data
Health data is retained for the same seven year period given the nature of medical information and potential long-term relevance.
7.3 Communications Data
Records of correspondence including WhatsApp messages are retained for the same seven year period as part of your interaction record.
7.4 Website Analytics Data
Anonymised website analytics data may be retained for longer periods for service improvement purposes.
7.5 Deletion
Following expiry of the applicable retention period your personal data will be securely deleted or anonymised.
PART 8 — YOUR RIGHTS
8.1 Rights Under UK GDPR
You have the following rights in relation to your personal data:
(a) Right of access — to request a copy of the personal data we hold about you; (b) Right to rectification — to request correction of inaccurate or incomplete personal data; (c) Right to erasure — to request deletion of your personal data in certain circumstances including where it is no longer necessary for the purposes for which it was collected; (d) Right to restrict processing — to request that we limit how we use your personal data in certain circumstances; (e) Right to data portability — to receive your personal data in a structured, commonly used, and machine-readable format in certain circumstances; (f) Right to object — to object to processing based on legitimate interests or for direct marketing purposes; (g) Right to withdraw consent — to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.
8.2 How to Exercise Your Rights
To exercise any of the above rights please contact us via the contact form on this Website. We will respond to your request within one calendar month of receipt. We may request verification of your identity before processing your request.
8.3 No Fee
You will not ordinarily be charged a fee to exercise your rights. However, we reserve the right to charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive.
PART 9 — DATA SECURITY
9.1 Security Measures
Turkey Laser Guide implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:
(a) Secure encrypted communication channels; (b) Restricted access to personal data on a need-to-know basis; (c) Regular review of our data handling practices; (d) Use of reputable third-party service providers including Stripe for payment processing.
9.2 Data Breaches
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach where required by law. Where the breach is likely to result in a high risk to your rights and freedoms we will also notify you directly without undue delay.
9.3 Third Party Security
While we take reasonable steps to ensure the security of data shared with Medical Providers and other third parties, Turkey Laser Guide cannot guarantee the security practices of independent third parties. Users are encouraged to review the privacy policies of any Medical Provider directly.
PART 10 — COOKIES
This Website uses cookies. Full details of the cookies we use and how to manage them are set out in our Cookie Policy. By continuing to use this Website you consent to our use of cookies in accordance with our Cookie Policy.
PART 11 — CHILDREN
This Website is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected data from a person under 18 please contact us via the contact form on this Website and we will take steps to delete it promptly.
PART 12 — LINKS TO THIRD-PARTY WEBSITES
This Website may contain links to third-party websites including Medical Provider websites. Turkey Laser Guide is not responsible for the privacy practices or content of any third-party website. We encourage you to review the privacy policy of any website you visit.
PART 13 — CHANGES TO THIS POLICY
Turkey Laser Guide reserves the right to update this Privacy Policy at any time. The current version will always be published on this Website with the date of last revision. Where changes are significant we will take reasonable steps to bring them to your attention. Your continued use of this Website following any update constitutes acceptance of the revised Privacy Policy.
PART 14 — COMPLAINTS
14.1 Contact Us First
If you have any concerns about how we handle your personal data we encourage you to contact us first via the contact form on this Website. We will endeavour to resolve any concern promptly and fairly.