Privacy Policy
Last Updated: October 2026
Introduction
TopHairLossClinic is an independent hair restoration information, comparison and referral platform operated under the trade name ANASA CREATIVE (GEMI No. 172112103000) (“TopHairLossClinic”, “we”, “our” or “us”).
We are committed to protecting the privacy and security of your personal data.
This Privacy Policy explains how personal data collected through the TopHairLossClinic platform is collected, used, stored, shared and protected in accordance with the EU General Data Protection Regulation (“GDPR”) and other applicable data protection legislation.
TopHairLossClinic is not a medical clinic and does not itself provide medical diagnoses, medical advice or medical treatment. Our role is to provide information and facilitate communication between individuals interested in hair restoration and independent clinics and medical providers.
Where you ask us to assist you in obtaining an assessment, treatment recommendation or quotation, we may, with the appropriate consent, forward relevant information to selected independent clinics or medical providers.
- Data Controller
TopHairLossClinic is operated under the trade name:
ANASA CREATIVE
GEMI No.: 172112103000
Website: tophairlossclinic.com
Email: contact@tophairlossclinic.com
For the purposes of this Privacy Policy, references to “TopHairLossClinic”, “we”, “our” or “us” refer to the operator of the TopHairLossClinic platform.
Independent clinics and medical providers receiving your information may act as separate and independent data controllers in relation to information they subsequently process for their own medical, administrative, regulatory and legal purposes.
- Personal Data We Collect
Depending on how you interact with TopHairLossClinic, we may collect and process the following categories of personal data.
Identification and Contact Information
This may include:
- Name
- Email address
- Telephone or WhatsApp number
- Age or date of birth, where requested
- Country of residence or nationality, where relevant
Information Relating to Hair Loss and Health
You may voluntarily provide information relating to:
- Your hair-loss condition or concerns
- Previous hair restoration procedures
- Previous or current hair-loss treatments
- Relevant medical history
- Medications or health conditions where relevant to your inquiry
- Other health-related information you choose to provide in connection with an assessment request
Information concerning your health may constitute special-category personal data under Article 9 GDPR.
Photographs and Images
You may provide photographs of your hair, scalp, hairline, crown, donor area, beard or other relevant areas for the purpose of obtaining an assessment from a clinic or medical provider.
Where such photographs reveal information concerning your health or are processed in connection with the assessment of your hair-loss condition, they may constitute health-related personal data.
Communication Data
We may process information contained in:
- Emails
- Website contact forms
- WhatsApp communications
- Telephone communications
- SMS messages
- Other communications with TopHairLossClinic
Technical Information
When you use our website, certain technical information may be collected, including:
- IP address
- Browser type
- Device information
- Website usage information
- Cookie identifiers
- Approximate location derived from technical information, where applicable
Consent Records
We may maintain records showing when, how and for what purposes you provided consent.
- How We Collect Your Personal Data
We primarily collect personal data directly from you when you:
- Submit an inquiry through our website
- Request assistance finding a clinic
- Upload or send photographs
- Contact us by email, telephone, WhatsApp or another communication channel
- Request quotations or assessments
- Subscribe to marketing communications
- Otherwise communicate with TopHairLossClinic
We may also receive relevant information from participating clinics where necessary to facilitate or follow up an inquiry or referral.
Certain technical information may be collected automatically through cookies and similar technologies when you use our website.
- How We Use Your Personal Data
We may use your personal data to:
- Respond to your inquiries
- Help identify potentially suitable hair restoration clinics or medical providers
- Facilitate communication between you and selected clinics
- Forward your inquiry to selected clinics where appropriate and authorised
- Allow independent clinics and medical providers to assess your case
- Obtain preliminary assessments, treatment proposals or quotations
- Provide information concerning clinic availability
- Follow up on inquiries and referrals
- Provide customer support
- Manage our relationship with you
- Maintain records of inquiries and referrals
- Improve the operation and functionality of our platform
- Protect our website and platform against misuse, fraud or security threats
- Comply with applicable legal and regulatory obligations
TopHairLossClinic does not make medical diagnoses or determine whether you are medically suitable for a particular procedure.
Any medical assessment, diagnosis, treatment recommendation or decision concerning your suitability for treatment is made independently by the relevant doctor, clinic or medical provider.
- Legal Bases for Processing
Under the GDPR, we rely on different legal bases depending on the nature and purpose of the processing.
Consent
We may rely on your consent where you have asked us to process or share information for a specific purpose.
Explicit Consent for Health-Related Information
Information concerning health is considered a special category of personal data under the GDPR.
Where information you provide constitutes health data or another special category of personal data, we may rely on your explicit consent under Article 9(2)(a) GDPR to process and share that information for the purposes explained to you.
This may include processing and sharing information concerning your hair loss, previous treatments, relevant medical history and photographs with selected clinics or medical providers.
Steps Taken at Your Request
We may process ordinary personal data where necessary to respond to your request or take steps requested by you in connection with the services offered through TopHairLossClinic.
Legitimate Interests
We may process certain non-sensitive personal data where necessary for our legitimate interests, including:
- Operating and improving TopHairLossClinic
- Responding to communications
- Maintaining platform security
- Preventing fraud or misuse
- Managing business relationships
We rely on legitimate interests only where those interests are not overridden by your fundamental rights and freedoms.
Legal Obligations
We may process personal data where necessary to comply with applicable legal, regulatory, accounting or other obligations.
Where processing is based on consent, you may withdraw your consent at any time by contacting:
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
- Sharing Information with Hair Restoration Clinics
A core function of TopHairLossClinic is helping individuals connect with independent hair restoration clinics and medical providers.
Where you request this service and have provided the necessary consent, we may share relevant information with selected clinics or medical providers.
Information shared may include:
- Your name
- Contact information
- Hair-loss information
- Relevant medical or treatment information you have provided
- Photographs
- Your treatment preferences
- Other information reasonably necessary for a clinic to evaluate your inquiry
The purpose of sharing this information is to allow selected clinics to assess your case and, where appropriate, provide:
- Preliminary assessments
- Potential treatment options
- Treatment recommendations
- Availability
- Quotations or estimated costs
- Further consultation opportunities
TopHairLossClinic does not itself perform the medical assessment.
The receiving clinic or medical provider is responsible for determining medical suitability and any proposed treatment.
- Sharing Your Case with Multiple Clinics
One of the services provided by TopHairLossClinic is helping users compare appropriate hair restoration providers.
Where you specifically consent to this service, we may send your inquiry to more than one selected clinic or medical provider so that you can receive and compare assessments, treatment options, availability and quotations.
We will only share information reasonably relevant to this purpose.
You may withdraw your consent to future sharing at any time by contacting:
Withdrawal of consent will prevent TopHairLossClinic from carrying out future consent-based sharing but will not affect processing that lawfully occurred before your consent was withdrawn.
Information already received by an independent clinic may continue to be processed by that clinic where it has an independent lawful basis or legal obligation to do so.
- Independent Clinics and Medical Providers
Clinics, doctors and other medical providers introduced through TopHairLossClinic are independent providers.
TopHairLossClinic does not employ or control these providers unless explicitly stated otherwise.
Once your information has been lawfully transferred to an independent clinic or medical provider, that provider may act as an independent data controller in relation to its subsequent processing of your personal data.
The provider is responsible for its own compliance with applicable privacy, data protection and healthcare laws.
We encourage you to review the privacy policy of any clinic or medical provider with which you decide to proceed.
TopHairLossClinic does not control medical decisions, diagnoses, treatment recommendations, procedures or medical records maintained independently by clinics and medical providers.
- Service Providers and Other Recipients
We may use trusted third-party service providers to assist us in operating TopHairLossClinic.
These may include providers of:
- Website hosting
- Email and communication services
- IT and cybersecurity services
- Customer relationship management systems
- Analytics
- Website functionality
- Data storage
- Professional legal, accounting or administrative services
Where a service provider processes personal data on our behalf, we take appropriate measures to ensure that processing is subject to appropriate contractual and data-protection safeguards.
We may also disclose personal data where required by law, regulation, court order or a competent regulatory or public authority.
- International Data Transfers
TopHairLossClinic may work with clinics, medical providers and service providers located both within and outside the European Economic Area (“EEA”).
Where you ask us to assist you in obtaining an assessment or quotation from a provider located outside the EEA, your personal data may need to be transferred internationally.
Where the GDPR requires safeguards for such transfers, appropriate measures will be used as applicable.
These may include:
- Transfers to countries recognised by the European Commission as providing an adequate level of data protection
- European Commission-approved Standard Contractual Clauses (“SCCs”), together with supplementary safeguards where appropriate
- Another transfer mechanism permitted under applicable data protection legislation
Where a proposed transfer requires your explicit consent under applicable law, relevant information will be provided and your consent obtained before the transfer.
You may contact us for further information concerning safeguards applicable to international transfers involving your personal data.
- Data Security
We take appropriate technical and organisational measures designed to protect personal data against:
- Unauthorised access
- Unauthorised disclosure
- Accidental loss
- Alteration
- Misuse
- Destruction
Depending on the circumstances, these measures may include:
- Access controls
- Secure communications
- Encryption where appropriate
- Authentication measures
- Restricted access to personal information
- Data minimisation
- Appropriate organisational and security procedures
However, no method of electronic transmission or storage can be guaranteed to be completely secure.
- Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, accounting, regulatory or dispute-resolution requirements.
Retention periods may vary depending on the nature of the information and our relationship with you.
When determining appropriate retention periods, we consider:
- The purpose for which the information was collected
- Whether an inquiry or referral remains active
- The nature and sensitivity of the information
- Applicable legal or regulatory requirements
- The need to establish, exercise or defend legal claims
Where information is no longer required, it will be deleted, anonymised or otherwise securely disposed of in accordance with our applicable procedures.
You may request deletion of your personal data, subject to applicable legal exceptions and our obligations to retain certain information.
- Your Data Protection Rights
Subject to the conditions and exceptions established by applicable law, you may have the right to:
- Access – request information about and copies of personal data we hold about you
- Rectification – request correction of inaccurate or incomplete personal data
- Erasure – request deletion of your personal data in certain circumstances
- Restriction – request restriction of processing in certain circumstances
- Object – object to certain processing based on legitimate interests
- Data Portability – receive certain personal data in a structured, commonly used and machine-readable format where applicable
- Withdraw Consent – withdraw your consent at any time where processing is based on consent
- Lodge a Complaint – complain to a competent data protection supervisory authority
To exercise your rights, contact:
We may need to verify your identity before responding to certain requests.
- Marketing Communications
Marketing consent is separate from consent to process your inquiry or share your case with clinics.
You are not required to consent to marketing in order to use TopHairLossClinic’s inquiry, comparison or referral services.
Where required by applicable law, we will only send electronic direct marketing communications after obtaining the appropriate consent.
You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting:
Withdrawal from marketing communications will not affect communications that are necessary to respond to or manage an inquiry you have made.
- Telephone, WhatsApp and SMS Communications
Where you communicate with TopHairLossClinic through telephone, WhatsApp, SMS or similar communication services, we may process information contained in those communications for the purpose of responding to and managing your inquiry.
We may also use these communication methods to provide information relating to:
- Your inquiry
- Clinic responses
- Consultation arrangements
- Appointment information
- Follow-ups requested in connection with your inquiry
If telephone calls are recorded, you will be appropriately informed and recordings will be handled in accordance with applicable data protection requirements.
Marketing communications through these channels will be handled separately in accordance with applicable marketing and data protection requirements.
- Cookies and Tracking Technologies
TopHairLossClinic may use cookies and similar technologies to:
- Operate the website
- Remember user preferences
- Maintain website security
- Understand how visitors use the website
- Measure website performance
- Support analytics and, where applicable, marketing activities
Cookies that are strictly necessary for operation of the website may be used without consent where permitted by law.
Where consent is required for analytics, advertising or other non-essential cookies, those technologies will only be activated after appropriate consent has been obtained.
You may manage your cookie preferences through the consent-management tools provided on the website.
Further information may be provided through our Cookie Policy or cookie settings.
- Third-Party Websites
The TopHairLossClinic website may contain links to websites operated by independent clinics, medical providers or other third parties.
TopHairLossClinic is not responsible for the privacy practices, content or security of independent third-party websites.
We encourage you to review the applicable privacy policy whenever you visit another website or provide personal information directly to another organisation.
- Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to:
- Our services
- Our business practices
- Technologies we use
- Applicable legal requirements
- Regulatory guidance
The latest version will be published on the TopHairLossClinic website and the “Last Updated” date will be revised accordingly.
Where appropriate, we may provide additional notice of significant changes.
- Contact Us
For questions concerning this Privacy Policy, the processing of your personal data, withdrawal of consent or the exercise of your data protection rights, please contact:
ANASA CREATIVE
Operator of TopHairLossClinic
GEMI No.: 172112103000
Website: tophairlossclinic.com
Email: contact@tophairlossclinic.com
- Complaints to a Supervisory Authority
If you believe that your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with a competent supervisory authority.
In Greece, the competent supervisory authority is the Hellenic Data Protection Authority (HDPA).
You may also have the right to lodge a complaint with the competent data protection authority in the EU or EEA country of your habitual residence, place of work or the place of the alleged infringement.