Italiano
DeutschThis policy explains how TopSurgery.it processes the personal data of people who visit www.topsurgery.it, fill in the contact form or write to us by email or WhatsApp. We know that information about health and gender identity is particularly sensitive, and we treat it with the utmost confidentiality.
1. Controller
TopSurgery.it, Istanbul, Turkey – email [email protected], phone / WhatsApp +90 212 963 09 02.
No Data Protection Officer has been appointed. For any question about how your data is processed, or to exercise your rights, you can write to [email protected] at any time.
2. Data we process
- Contact data: name (including the chosen name you give us), email, phone, country, preferred language.
- Content of communications: messages sent via form, email or WhatsApp, including any procedure of interest you select.
- Special categories of data (Art. 9 GDPR): information on health, gender identity and any chest photos – only if you provide them voluntarily and only with your explicit consent.
- Organisational data: travel dates, accommodation preferences and data needed for bookings and transfers.
- Technical data: IP address, browser type, date and time of access, recorded in server logs for security purposes, and the technical session cookie described in our cookie policy.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Answering contact and information requests | Pre-contractual steps at your request (Art. 6(1)(b)) |
| Preliminary assessment and sharing health data with the partner surgeon | Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) |
| Organising your stay and coordinating aftercare | Performance of a contract (Art. 6(1)(b)); explicit consent for health data (Art. 9(2)(a)) |
| Accounting and tax obligations | Legal obligation (Art. 6(1)(c)) |
| Website security and abuse prevention | Legitimate interest (Art. 6(1)(f)) |
We do not use your data for profiling or marketing without specific consent, and we never sell data. You can withdraw consent at any time by writing to [email protected]; this does not affect the lawfulness of processing carried out before withdrawal.
4. Recipients
- Partner surgeons and clinics in Turkey, limited to the data needed for assessment and surgery, and only with your explicit consent.
- Service providers acting as processors (website hosting, email service), bound by contract under Art. 28 GDPR.
- If you contact us via WhatsApp, messages pass through WhatsApp (Meta) under its own privacy policy. If you prefer, you can write to us by email instead.
- Hotels, transfer services and interpreters, limited to the organisational data required.
- Public authorities where required by law.
5. Transfers to Turkey
Turkey is a third country for which the European Commission has not adopted an adequacy decision. Data is transferred to partner clinics on the basis of appropriate safeguards under Art. 46 GDPR (for example standard contractual clauses) or, where these do not apply, on the basis of your explicit consent to the transfer under Art. 49(1)(a) GDPR after you have been informed of the possible risks. You can request a copy of the safeguards by writing to [email protected].
6. Retention
Enquiries that do not lead to surgery are kept for up to 24 months after the last contact unless you ask for earlier deletion. Photos and health data are deleted as soon as they are no longer needed for the purpose for which they were collected, and at the latest 12 months after aftercare ends. Accounting records are kept for the period required by law. Server logs are deleted automatically after a short period unless they are needed to investigate abuse.
7. Your rights
You have the right of access, rectification, erasure, restriction of processing, data portability and objection (Arts. 15–21 GDPR), as well as the right to withdraw consent at any time. To exercise them, write to [email protected]; we will reply within one month.
You also have the right to lodge a complaint with a supervisory authority, in particular the Italian Garante per la protezione dei dati personali or the authority in the country where you live or work.
8. Security
We use appropriate technical and organisational measures to protect your data, such as encrypted connections (HTTPS), access limited to authorised staff and private channels for sending photos. Please do not send chest photos through the website form – we will give you a private channel.
9. Cookies
TopSurgery.it only uses a technical session cookie, with no profiling or marketing cookies. Details are in our cookie policy.
10. Changes
This policy may be updated; the current version is always published on this page. Last updated: October 2026.