Privacy Statement Consumers

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 service. We help patients in Europe find and compare verified hair-transplant clinics in Turkey. We are not a clinic, we do not provide medical care, and we do not give medical advice. The clinics you are matched with are independent providers responsible for their own treatment and their own handling of your data once it reaches them.

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 patients and prospective patients who use hairlinq.com to request and compare clinic offers. Separate statements cover our clinic partners and general website visitors.

This service is intended for adults aged 18 or over. We do not knowingly collect data from anyone under 18.

3. What personal data we collect

Depending on how you use the service, we collect:

Identity and contact data: your name, email address, phone number, and country of residence.
Request details: information you provide about the treatment you are interested in, such as your goals, budget, and preferred timing.
Health data: information about your hair loss and scalp, and any photographs you upload of your head, hair or scalp. This is data concerning your health, which is a special category of personal data given extra protection under the law. We may also collect any additional medical details you choose to share, such as relevant medical history or medications.
Account and communication data: messages you send us, and records of your contact with us.
Technical data: IP address, device and browser information, and usage data collected through cookies and similar technologies (see our separate Cookie Statement).

We only ask for the health information needed to match you with suitable clinics and to let those clinics prepare a meaningful quote. You choose what to share.

4. Why we use your data and our legal basis

Purpose	Legal basis
To operate the comparison service and respond to your request	Your explicit consent, and our performance of the service you asked for
To process your health data and photographs so clinics can assess your request	Your explicit consent to the processing of special-category (health) data
To share your request with clinics you choose, once you opt in	Your explicit consent
To secure and maintain the website and prevent misuse	Our legitimate interest in running a safe, working service
To send you service messages about your request	Our legitimate interest, or your consent where required
To send marketing or newsletters, if applicable	Your explicit consent
To comply with legal obligations	Compliance with a legal obligation that applies to us

You can withdraw your consent at any time (see section 8). Withdrawing consent does not affect processing that already took place before you withdrew it.

5. How your request reaches clinics, and who we share data with

The opt-in step. When you submit a request, we match it to a limited number of clinics, a maximum of six per patient (up to five standard positions and one exclusive "Gold" position). We do not send your details to a clinic until you opt in to receive that clinic's quote. Only then is your request, including the health information and photographs you provided, shared with that clinic.

Who we share data with:

Clinics you opt in to. These are independent hair-transplant clinics located in Turkey. Once your data reaches a clinic, that clinic is an independent controller of your data and handles it under its own privacy terms and under Turkish data-protection law (KVKK).
Service providers who process data on our behalf, such as our hosting provider and communication tools. These providers act only on our instructions.
Authorities or advisers where we are legally required to disclose data.

We do not sell your personal data. Patients do not pay to use HairLinQ.

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 your personal data only as long as needed for the purposes above:

Request and health data: 12 months after the prospective patient's last activity.
Photographs: 60 days after submission or sharing with the chosen clinic(s).
Account and communication records: 24 months after last contact or until account deletion by user.
Data we must keep for legal reasons: for the period the law requires.

After these periods, we delete or anonymise your data.

7. International transfers

Your data is stored in the EU, but two situations involve data going to, or being accessed from, countries outside the European Economic Area that do not have an EU "adequacy" decision. We apply safeguards for both.

Clinics in Turkey. When you opt in, your data is transferred to the clinic you chose, in Turkey. Turkey does not have an EU adequacy decision, so we rely on Standard Contractual Clauses approved by the European Commission with our partner clinics, together with your explicit consent to the specific transfer.
Operational access from Bosnia and Herzegovina. Our business is run in the US, EU and we have remote teams in Bosnia . This means your data may be accessed from those countries for the purpose of operating the service. We apply appropriate safeguards and strict access controls to protect this access.

You can ask us for more information about these safeguards using the contact details in section 1.

8. Your rights

Under EU data-protection law you have the right to:

Access the personal data we hold about you.
Rectify data that is inaccurate or incomplete.
Erase your data ("right to be forgotten").
Restrict or object to our processing.
Data portability, to receive your data in a portable format.
Withdraw consent at any time, including consent to share your data with clinics and consent to process your health data.
Lodge a complaint with a supervisory authority (see section 9).

To exercise any of these rights, contact us at privacy[a]hairlinq.com. We will respond within the time the law requires, normally within one month.

9. Complaints

If you have a concern about how we handle your data, please contact us first so we can try to resolve it. You also have the right to complain to a data-protection supervisory authority. You can complain to the authority in your own EU country, and our lead authority is expected to be the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10. Automated matching

We match your request to clinics based on the information you provide. This matching does not make a decision that produces a legal effect or a similarly significant effect on you: you always choose whether to opt in to any clinic, and you choose which clinic, if any, to proceed with. [Confirm this reflects the final matching logic.]

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 and to manage your choices.

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