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Privacy Notice

Quick answer: If you send an enquiry, I collect your contact details and hair loss information (including any photos) to assess your case. If you proceed, that information is shared with the specific partner clinic treating you, including a clinic in Turkey. Turkey does not have a UK or EU data adequacy decision, so that transfer is covered by Standard Contractual Clauses signed with the clinic, not just your consent.

Who I am

Resolute Hair UG (haftungsbeschränkt), Berlin, Germany, is the controller of your personal data for the purposes of UK GDPR and EU GDPR. For any privacy question, contact jon@resolutehair.com.

What I collect

Why I collect it, and on what basis

PurposeLegal basis
Responding to your enquiry and assessing candidacySteps taken at your request, before entering a contract (UK/EU GDPR Art 6(1)(b))
Sharing your hair loss information and photos with a partner clinicYour explicit consent (Art 9(2)(a), for special category health data)
Coordinating your booking and treatmentPerformance of a contract with you (Art 6(1)(b))
Occasional updates and marketingYour consent, given separately and always optional (Art 6(1)(a))

Who your data is shared with

Your hair loss information is shared only with the specific partner clinic relevant to your enquiry, not with every clinic in the network. Each partner clinic is contractually bound to use your data solely to assess and provide your treatment, and to keep it confidential.

Service providers

I also use a small number of service providers to run Resolute Hair. They process personal data only on my instructions, under a data processing agreement, and are not permitted to use it for their own purposes:

Some of these providers are based in, or may transfer data to, the United States. Where that happens, the transfer is protected by the EU-US Data Privacy Framework or by Standard Contractual Clauses, as applicable.

International transfers

Partner clinics are located in Turkey, which does not have a UK or EU data adequacy decision. Because every patient referral involves this transfer, I don't rely on your consent alone as the basis for it. Before any clinic joins the network, Resolute Hair signs Standard Contractual Clauses with that clinic, the standard safeguard recognised under Article 46 GDPR for transfers to a country without an adequacy decision. Your consent (above) covers the sharing of your health data specifically; the Standard Contractual Clauses are what make the international transfer itself lawful on an ongoing basis.

How long I keep it

If you don't proceed past an initial enquiry, your details are kept only as long as needed to respond to you, and are deleted after a reasonable period of inactivity. If you book treatment, your records are kept for as long as needed to provide treatment and aftercare, and afterwards in line with applicable legal and professional retention requirements.

Your rights

You can ask to access, correct, delete, or restrict the personal data I hold about you, and you can withdraw consent at any time without affecting anything done before that withdrawal. To exercise any of these, email jon@resolutehair.com. If you're not satisfied with my response, you can complain to the UK Information Commissioner's Office (ico.org.uk) or, if you're in the EU, your local data protection authority.

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Questions about how your data is handled? Ask me directly.

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This notice describes how Resolute Hair handles personal data. It is general information, not a substitute for independent legal advice, and will be reviewed and updated as the business and its clinic network develop.

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