Privacy Statement Clinics
1. Who we are
HairLinQ is a service operated by ScalarRatio LLC, a company registered in the State of Wyoming, United States, at 75 E 3rd St, Sheridan, WY 82801. HairLinQ is a trade name of ScalarRatio LLC. In this statement, "HairLinQ", "we", "us" and "our" refer to ScalarRatio LLC.
HairLinQ is a comparison and introduction platform that connects prospective patients in Europe with verified hair-transplant clinics in Turkey. We are an introducer, not a medical provider.
For any privacy question or to exercise your rights, contact us at privacy[a]hairlinq.com.
2. Who this statement is for
This statement explains how we handle the personal data of the individuals who represent, work at, or act on behalf of a clinic in their dealings with HairLinQ. That includes the person who registers a clinic, account users, owners and managers, and billing and sales contacts.
It does not cover:
The clinic as a company. Company information such as the clinic's registered name, address and certificate is not personal data.
Prospective-patient data. How we handle prospective patients' data is explained in our separate Patient Privacy Statement. When a prospective patient opts in and their request reaches your clinic, your clinic becomes an independent controller of that data, with its own obligations, as set out in our clinic data-sharing agreement.
3. What personal data we collect
Depending on how your clinic uses the platform, we collect:
Identity and contact data: name, job title, business email address, and business phone number of the individuals dealing with us.
Account data: login credentials, account settings, and activity on the platform.
Verification data: documents and details you provide so we can verify the clinic, including the clinic's Ministry of Health International Health Tourism Authorization Certificate and the names of responsible persons shown on it.
Billing and transaction data: records of credit purchases, leads accepted, invoices and payment details (note: payment-card data is handled by our payment provider, not stored by us).
Communications: messages, emails and call records between you and our sales and support teams.
Prospect data: where we contact a clinic that has not yet signed up, the business-contact details we use for that outreach.
Technical data: IP address, device and browser information, and usage data collected through cookies and similar technologies (see our separate Cookie Statement).
4. Why we use your data and our legal basis
Purpose | Legal basis |
|---|---|
To set up and manage your clinic account and provide the platform | Performance of our contract with your clinic |
To verify the clinic's eligibility and authorization certificate | Our legitimate interest in a trusted, compliant marketplace, and compliance with our own legal obligations |
To process credit purchases, leads and invoicing | Performance of our contract, and compliance with legal obligations |
To provide sales and customer support | Performance of our contract, and our legitimate interest in running the service |
To contact clinics about joining HairLinQ (outreach) | Our legitimate interest in business-to-business marketing (you can object at any time) |
To send service and account messages | Performance of our contract, or our legitimate interest |
To secure the platform and prevent fraud or misuse | Our legitimate interest in a safe, working service |
To meet accounting, tax and other legal duties | Compliance with a legal obligation |
Where we rely on legitimate interests, you have the right to object (see section 8).
5. Who we share your data with
Service providers who process data on our behalf, such as our hosting provider, payment processor, and communication tools. They act only on our instructions.
Professional advisers and authorities where we are legally required to disclose data.
We do not share clinic representatives' personal data with prospective patients or with other clinics, and we do not sell your personal data.
6. Where your data is stored, and how long we keep it
Your data is hosted on a secure server located in Germany, within the European Union. We keep personal data only as long as needed for the purposes above, then delete or anonymise it. Our retention periods are:
Data | Retention period |
|---|---|
Account, profile and contract data | For the duration of the business relationship, then deleted or anonymised within 12 months of account closure, unless a longer period below applies |
Verification and certificate documents | Duration of the relationship plus 24 months, so we can evidence that we verified the clinic's eligibility |
Financial and accounting records (invoices, credit purchases, payments) | 7 years or equal to required fiscal retention obligation; |
Communications (sales and support) | 24 months after last contact |
Prospect / outreach data (clinics contacted that have not signed up) | 12 months since last meaningful contact, or until you ask us to stop, whichever is sooner |
Consent records (where we rely on consent, e.g. marketing) | Duration of the processing plus 5 years, for accountability |
Login, server and security logs, and technical data | 90 days |
7. International access and transfers
Your data is stored in the EU. Our business operates in the US, EU & Bosnia, which means your data may be accessed from those countries to run the service. Bosnia does not have an EU adequacy decision, so we apply appropriate safeguards and strict access controls to protect that access.
If your clinic is based in Turkey, note that we process your representatives' data under EU data-protection law, and your clinic separately remains subject to Turkish data-protection law (KVKK) for the data it handles.
8. Your rights
Under EU data-protection law you have the right to access, rectify, erase, restrict, and port your personal data, to object to processing based on our legitimate interests, and to withdraw any consent you have given. Some of these rights are limited where we need the data to perform our contract with your clinic or to meet a legal obligation, for example we must keep accounting records for the statutory period even if you ask us to erase them.
To exercise any right, contact us at privacy[a]hairlinq.com. We will respond within the time the law requires, normally within one month.
9. How we contact clinics
We contact clinics by phone and by email from @hairlinq.com addresses to introduce the platform and to manage your account. If you do not want to receive outreach or marketing from us, you can opt out at any time by contacting us or using the unsubscribe link in our emails. Opting out of marketing does not stop essential service and account messages.
10. Complaints
If you have a concern about how we handle your data, please contact us first. You also have the right to complain to a supervisory authority. Our lead authority is expected to be the Dutch Data Protection Authority. Clinic representatives in Turkey may also have avenues under Turkish data-protection law.
11. How we protect your data
We use appropriate technical and organisational measures to protect your data, including EU-based hosting, access controls, and safeguards for access from outside the EEA. No method of transmission or storage is completely secure, but we work to protect your data and to respond promptly to any incident.
12. Cookies
We use cookies and similar technologies on hairlinq.com. Non-essential cookies are only used with your consent. See our separate Cookie Statement for details.
13. Changes to this statement
We may update this statement from time to time. We will post the updated version here with a new "last updated" date, and where changes are significant we will take reasonable steps to inform you.
14. Contact
ScalarRatio LLC, trading as HairLinQ, 75 E 3rd St, Sheridan, WY 82801, United States. Privacy contact: privacy[a]hairlinq.com