Privacy Policy

1. Who We Are

Foxpare ("Foxpare", "we", "us", "our") operates the website foxpare.com — a free, independent search and matching tool that helps users find hair transplant clinics in Turkey that match their criteria. We are not a medical provider and do not perform or arrange medical procedures.

For any privacy-related queries, contact us at: info@foxpare.com

2. Information We Collect

We collect the following categories of personal data:

2.1 Information you provide directly

• Email address — when you sign up, request matches, or contact us.
• Name — when you create an account or contact us.
• Chat answers — the responses you give in the Foxpare matching conversation (e.g. target area, technique preferences, budget, city, extent of hair loss, qualification preferences). These are used to match you with suitable clinics.
• Photos (optional) — if you choose to upload scalp/hair photos so the clinics you select can give a more accurate assessment. Photos are only processed with your explicit consent and are auto-deleted after the retention period below.
• Messages and enquiries — content of any messages you send us.
• Emailed results link — if you use the "Email me these results" feature on the matching flow, we store your email address and your chat answers so we can send you a private link back to your matches. The email is used only to deliver that link (and for follow-ups only if you separately consented elsewhere). We do not store the specific matched clinic list — matches are recomputed from current clinic data when you open the link.

2.2 Information collected automatically

• Device and browser information (IP address, browser type, operating system).
• Usage data (pages visited, time spent, links clicked, referring URL).
• Cookie data — as described in our Cookie Policy.

2.3 Information from third parties

We display clinic data sourced from publicly available information. We do not receive personal data from clinics unless they contact us directly to request or manage a listing.

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide and improve the Foxpare platform and its features.
• To respond to enquiries and support requests.
• To send you newsletters or updates, if you have opted in.
• To analyse how users interact with the Website (analytics) and improve the user experience.
• To comply with our legal obligations.
• To detect and prevent fraud, abuse, or security incidents.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal Basis for Processing

Where applicable under GDPR or UK GDPR, we process your personal data on the following legal bases:

• Consent — for newsletter sign-ups and non-essential cookies.
• Legitimate interests — for analytics, improving the platform, and fraud prevention, where your interests do not override ours.
• Legal obligation — where processing is required by law.
• Contract — where processing is necessary to fulfil a request you have made.

5. Sharing Your Information

We do not sell, rent, or trade your personal data to third parties. We share data only as follows:

• Clinics you select — when you choose to request a match, quote or assessment from one or more clinics, we share with those clinics only the information needed for them to respond (your chat answers, contact details, and any photos you have chosen to include). Once your information has been shared, each clinic acts as a separate, independent data controller for their own processing, governed by their own privacy policy. We are not responsible for how a clinic subsequently handles your data.
• Service providers — hosting, email delivery, and analytics providers (Google Analytics 4 and Microsoft Clarity) acting as our processors.
• Legal authorities — where required by law, court order, or to protect our rights.

All third-party service providers are contractually required to handle your data securely and only for the purposes we specify.

Microsoft Clarity

With your consent, we use Microsoft Clarity to understand how visitors use Foxpare. Clarity captures anonymised interaction data — mouse movement, clicks, scrolling and pages visited — and presents it as session replays and aggregated heatmaps. Text entered into input fields is masked. We use this only to identify usability problems and improve the site. Microsoft acts as a processor and may transfer data outside Türkiye and the EEA. You can withdraw consent at any time via "Cookie settings" in the footer.

Neither Google Analytics nor Microsoft Clarity is loaded until you actively opt in to that category. If you reject or ignore the cookie banner, these scripts are never loaded and set no cookies.

We do not collect patient contact details through the clinic search flow, and our clinic click tracking is anonymous and aggregate only — no IP address, no session identifier and no user identifier is stored.

Anonymous page view counting

Separately from Google Analytics and Microsoft Clarity, we count page views ourselves, anonymously and in aggregate. For each page view we store only the page path, the referring website's domain (for example "google.com"), a two-letter country code, whether the device is a phone, tablet or desktop, and whether the page was viewed in English or German.

We store no cookies, no IP addresses, no browser or device fingerprints, no session identifiers and no user identifiers of any kind for this purpose. Your IP address is used only momentarily, at the time of the request, to derive the country code, and is then discarded — it is never stored. The resulting records cannot be linked to you or to each other, so they are not personal data and this counting therefore runs without consent. Google Analytics 4 and Microsoft Clarity remain fully consent-gated and are not loaded unless you opt in.

6. International Data Transfers

Foxpare is based in Turkey. If you are located in the EEA or UK, your data may be transferred to and processed in Turkey or by providers located in countries outside the EEA/UK, including the United States (e.g. Google Analytics 4 and Microsoft Clarity).

Where we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or equivalent mechanisms.

7. Data Retention & Auto-Deletion

We retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy, or as required by law. Specifically:

• Chat answers / matching data — retained for 12 months from the end of the session, then automatically deleted or anonymised.
• Uploaded photos — auto-deleted from our servers within 30 days of being sent to the clinics you selected. Clinics that received them retain them under their own retention rules.
• Account data — retained while your account is active, plus 12 months after closure.
• Newsletter data — retained until you unsubscribe.
• Enquiry/contact data — retained for up to 2 years from the date of contact.
• Analytics data — Google Analytics 4 up to 14 months; Microsoft Clarity up to 12 months.

8. Your Rights (GDPR & KVKK)

Depending on your location, you have rights under the EU/UK General Data Protection Regulation (GDPR) and/or the Turkish Personal Data Protection Law no. 6698 (KVKK):

• Access — request a copy of the personal data we hold about you.
• Rectification — request correction of inaccurate or incomplete data.
• Erasure / deletion — request deletion of your personal data, subject to legal obligations.
• Restriction — request that we restrict processing in certain circumstances.
• Portability — receive your data in a structured, machine-readable format.
• Objection — object to processing based on legitimate interests.
• Withdraw consent — at any time, where processing is based on consent (e.g. photos, analytics cookies).
• KVKK-specific — to learn whether your data is processed, the purposes of processing, the third parties to whom it is transferred, and to object to outcomes produced solely by automated analysis, as set out in Article 11 of the KVKK. See our KVKK Aydınlatma Metni for details.

To exercise any of these rights, contact us at info@foxpare.com. We respond within 30 days. You also have the right to lodge a complaint with your local data protection authority, or with the Turkish Personal Data Protection Authority (KVKK Kurulu).

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. However, no method of internet transmission or electronic storage is 100% secure. We encourage you to use strong passwords and to protect your account credentials.

10. Children's Privacy

Foxpare is not directed to children under the age of 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately at info@foxpare.com and we will delete it promptly.

11. Links to Third-Party Websites

Our Website contains links to clinic websites and other third-party services. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this document will be revised accordingly. Where changes are material, we will notify you via a prominent notice on our Website or by email where appropriate.

13. Contact Us

For any questions about this Privacy Policy or how we handle your personal data, please contact: info@foxpare.com. We aim to respond to all enquiries within 5 business days.