Privacy Policy
Your privacy and data protection are our top priorities
Effective Date: August 12, 2025
Last Updated: August 12, 2025
1. Introduction
Welcome to Electivio. We are committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how Electivio ("we," "us," or "our") collects, uses, discloses, and protects your personal data when you use our website (electivio.com), inquire about our services, or engage with us for hair transplant facilitation in Turkey.
Our registered company, Electivio AG, is the primary data controller for the information collected. We are a company based in Switzerland, and we adhere to the Swiss Federal Act on Data Protection (nFADP), the EU General Data Protection Regulation (GDPR), and the UK General Data Protection Regulation (UK GDPR) in our data processing activities.
2. Data Controller Information
The entity responsible for processing your personal data is:
Electivio AG
Talstrasse 88, 8808 Pfäffikon SZ, Switzerland
For any questions or requests regarding your data, please contact our Data Protection representative at privacy@electivio.com.
3. What Personal Data We Collect
We collect information to provide and improve our services. The types of personal data we collect depend on your interaction with us:
Information You Provide Directly:
- Contact Information: Your full name, email address, phone number, and country of residence when you fill out a contact form, book a consultation, or communicate with us.
- Health Information: Information about your health, specifically related to hair loss and your suitability for a hair transplant procedure. This may include photographs you voluntarily submit for assessment. This is considered "special category" or "sensitive" data, and we will only process it with your explicit consent.
- Communication Records: A record of your correspondence with us, including emails, live chat transcripts, and summaries of phone calls.
Information We Collect Automatically:
- Technical & Usage Data: When you visit our website, we automatically collect data such as your IP address, browser type and version, time zone setting, operating system, and device type. We also collect information about your visit, including the pages you viewed, the time spent on pages, and your interaction with our site (clicks, scrolling). This data is collected using tools like Google Analytics and Zoho PageSense.
Information from Third Parties:
- Call Center Data: If you interact with our third-party call center platform, they will securely transmit your inquiry details and contact information to us.
- Partner Data: We may receive information from our partner clinics in Turkey regarding the planning and execution of your procedure.
4. How We Use Your Personal Data & Our Legal Basis for Processing
We only use your personal data when the law allows us to. Our primary purposes and legal bases are:
Purpose of Processing | Type of Data | Legal Basis for Processing (under GDPR/nFADP) |
---|---|---|
To respond to your inquiries and provide a consultation. | Contact Info, Health Info | Explicit Consent (for health data); Legitimate Interest (to respond to your request). |
To facilitate your medical procedure with our partner clinics. | Contact Info, Health Info | Performance of a contract with you; Explicit Consent (for sharing health data with clinics). |
To communicate with you about your procedure and our services. | Contact Info | Performance of a contract; Legitimate Interest. |
To improve our website and services. | Technical & Usage Data | Legitimate Interest (to ensure our website is effective and secure). |
For marketing and promotional communications (with your permission). | Contact Info | Consent (You can opt-out at any time). |
To comply with legal and regulatory obligations. | All relevant data | Legal Obligation. |
Special Note on Health Data: We will always ask for your explicit consent before collecting or processing any health-related information. You have the right to withdraw this consent at any time.
5. Data Sharing and Disclosure
We do not sell your personal data. We may share your data with the following trusted third parties to provide our services:
- Partner Clinics in Turkey: We will share your personal and health information with your selected clinic in Turkey to facilitate your consultation and procedure. We only do this with your explicit consent.
- Legal and Regulatory Authorities: We may disclose your data if required by law or in response to a valid legal request.
We have agreements in place with all third parties to ensure they protect your data to the same high standards we do.
6. International Data Transfers
Your data may be transferred and processed in countries outside of your country of residence, including Switzerland, the European Union, the United Kingdom, the USA (where some of our tech providers are based), and Turkey.
- Transfers to Switzerland: The EU and UK have recognized Switzerland as providing an adequate level of data protection, allowing for smooth data flow.
- Transfers to Turkey: Turkey is not currently recognized as having an adequate level of data protection by the EU or UK. To protect your data, we will only transfer your personal information (specifically to partner clinics) based on your explicit consent and by using legally-approved safeguards, such as Standard Contractual Clauses (SCCs), which contractually oblige the receiving party to protect your data to EU/UK standards.
- Transfers to Other Countries (e.g., USA): For transfers to other countries, we rely on adequacy decisions or other appropriate safeguards like SCCs to ensure the protection of your data.
7. Data Security
We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. These measures include data encryption, access control, and regular security reviews.
8. Data Retention
We will only retain your personal data for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As a general rule, client data related to a medical procedure will be retained for the period required by medical and financial regulations, after which it will be securely deleted.
9. Your Data Protection Rights
Under data protection law (GDPR, UK GDPR, nFADP), you have various rights, including:
- The Right to Access: You can request a copy of the personal data we hold about you.
- The Right to Rectification: You can request that we correct any inaccurate or incomplete data.
- The Right to Erasure (The "Right to be Forgotten"): You can request that we delete your personal data where there is no compelling reason for us to keep it.
- The Right to Restrict Processing: You can ask us to suspend the processing of your personal data in certain circumstances.
- The Right to Data Portability: You can request the transfer of your personal data to you or a third party in a machine-readable format.
- The Right to Object: You can object to our processing of your data where we are relying on a legitimate interest.
- The Right to Withdraw Consent: Where we rely on your consent to process data (especially health and marketing data), you can withdraw that consent at any time.
To exercise any of these rights, please contact us at privacy@electivio.com.
You also have the right to lodge a complaint with a supervisory authority:
- For UK residents: The Information Commissioner's Office (ICO).
- For German residents: The relevant data protection authority for your federal state (Landesdatenschutzbehörde).
- For Swiss residents/contacts: The Federal Data Protection and Information Commissioner (FDPIC).
10. Cookies Policy
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience and to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy at https://www.electivio.com/en-GB/cookie-policy.
11. Changes to This Privacy Policy
We may update this policy from time to time. The "Last Updated" date at the top of this page indicates when it was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
12. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Email: privacy@electivio.com
Address: Electivio AG, Talstrasse 88, 8808 Pfäffikon SZ, Switzerland