1. Introduction

Welcome to LuxCare Agency ("we," "us," or "our"), a health tourism company facilitating medical treatments and travel services. We are committed to protecting your personal data, including sensitive health information, and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at www.luxcareagency.com (the "Website") or engage with our health tourism services, including our use of cookies and tracking technologies such as Google Analytics and Facebook Pixel. This policy complies with the General Data Protection Regulation (GDPR) as applicable in the European Union and the United Kingdom, the Turkish Personal Data Protection Law (KVKK), and other relevant data protection laws.

As a health tourism provider, we handle special categories of personal data, such as health information, which require enhanced protections. By using our Website or services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Website or our services.

2. Data Controller

LuxCare Agency is the data controller responsible for your personal data. Our contact details are:

3. Information We Collect

We may collect and process the following types of information:

3.1 Personal Data

• Contact Information: Name, email address, phone number, or other details you provide when contacting us via forms, email, or WhatsApp.
• Account Information: If you create an account, we may collect your username, password (encrypted), and related details.
• Correspondence: Records of communications with us, including inquiries or complaints.
• Health Data: Medical history, treatment details, diagnoses, test results, or other health-related information you provide to facilitate medical tourism services. This is considered a special category of personal data under GDPR and KVKK, requiring explicit consent.

3.2 Non-Personal Data

• Usage Data: Information about how you interact with our Website, such as pages visited, time spent, and referral sources.
• Device Information: IP address, browser type, operating system, and device identifiers.
• Cookies and Tracking Data: Data collected via cookies and similar technologies (see Section 5).

4. How We Use Your Information

We use your information for the following purposes:

• To Provide Health Tourism Services: Coordinate medical treatments, communicate with healthcare providers, and arrange travel logistics based on your health data and preferences.
• To Respond to Inquiries: Answer questions, process requests, and provide customer support.
• To Improve Our Website and Services: Analyze user behavior to enhance functionality and user experience.
• Marketing and Advertising: With your consent, deliver personalized ads via Google Ads and Facebook Pixel.
• Legal Compliance: Comply with applicable laws, regulations, or legal processes, including GDPR and KVKK.
• Security: Protect against fraud, unauthorized access, or other illegal activities.

5. Cookies and Tracking Technologies

Our Website uses cookies and similar technologies to enhance your experience, analyze usage, and deliver personalized content. Cookies are small text files stored on your device. We use the following types of cookies:

5.1 Types of Cookies

• Essential Cookies: Necessary for the Website to function, such as maintaining user sessions. These do not require consent.
• Analytics Cookies: Collect anonymized data on user behavior via Google Analytics to improve our Website. Consent is required.
• Advertising Cookies: Enable personalized ads through Google Ads and Facebook Pixel. Consent is required.

5.2 Third-Party Services

We use the following third-party services that may set cookies:

• Google Analytics: Tracks and reports Website traffic. Data is anonymized unless you consent to analytics cookies. See Google’s Privacy Policy.
• Facebook Pixel: Tracks user actions for advertising purposes. Only active with your consent for advertising cookies. See Meta’s Privacy Policy.

5.3 Cookie Consent

When you visit our Website, a cookie consent banner allows you to manage your preferences. You can accept all cookies, reject non-essential cookies, or customize your choices. Essential cookies are always active and do not require consent. You can revisit your preferences at any time via the "Manage Cookies" link in the footer.

We use Google Consent Mode v2 to ensure that Google Analytics and Google Ads only process data with your explicit consent. Similarly, Facebook Pixel only activates after you consent to advertising cookies.

6. Sharing with Medical Service Providers

To provide health tourism services, we may share your personal data, including health data, with trusted medical service providers such as hospitals, clinics, or doctors. These providers are carefully selected and contractually obligated to comply with GDPR, KVKK, and other applicable data protection laws. We only share the minimum data necessary to facilitate your treatment or travel arrangements.

Before sharing health data, we obtain your explicit consent through our service agreements or consent forms. You may withdraw this consent at any time, subject to legal or contractual restrictions.

7. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Explicit Consent: For processing special categories of data (e.g., health data), non-essential cookies (analytics and advertising), and certain marketing activities.
• Contract: To fulfill service agreements, such as arranging medical treatments or travel logistics.
• Legitimate Interests: For essential cookies, Website improvements, and security measures, where your interests do not override our legitimate needs.
• Legal Obligation: To comply with applicable laws or regulations, including GDPR and KVKK.

8. Data Sharing and International Transfers

We may share your data with:

• Medical Service Providers: Hospitals, clinics, or doctors to facilitate your treatment (see Section 6).
• Service Providers: Third parties like Google and Meta for analytics and advertising, only with your consent.
• Legal Authorities: If required by law or to protect our rights.

As a health tourism provider, we may transfer your data to medical service providers or partners located outside the EU/UK or Türkiye, such as in countries where treatments are performed. We ensure these transfers comply with GDPR and KVKK through Standard Contractual Clauses (SCCs), Data Protection Agreements, or other approved mechanisms. We only transfer data with your explicit consent and take measures to ensure equivalent data protection standards.

9. Your Data Protection Rights

Under GDPR and KVKK, you have the following rights regarding your personal data:

• Access: Request a copy of your personal data, including health data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data (right to be forgotten), subject to legal retention obligations.
• Restriction: Limit how we process your data.
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests, including marketing.
• Withdraw Consent: Revoke consent for non-essential cookies, health data processing, or other activities at any time.
• KVKK-Specific Rights: Under Turkish law, you have the right to be informed about data processing, refuse automated decision-making, and seek compensation for damages caused by unlawful processing.

To exercise these rights, contact us at info@luxcareagency.com. We will respond within one month, though complex requests may take longer. If you’re unsatisfied, you can lodge a complaint with a supervisory authority, such as the UK Information Commissioner’s Office (ICO), an EU data protection authority, or the Turkish Personal Data Protection Authority (KVKK Kurumu).

10. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

• Contact information is kept until your inquiry is resolved or for up to 3 years for customer service purposes.
• Health data is retained for the duration of your treatment process and up to 5 years thereafter, as required by medical and legal standards, unless you request earlier deletion (subject to legal obligations).
• Cookie data is stored for up to 12 months, as per your consent settings.
• Analytics data is anonymized and retained for up to 26 months by Google Analytics.

Data no longer needed is securely deleted or anonymized.

11. Security

We implement technical and organizational measures to protect your data, including encryption, secure servers, access controls, and regular security audits. Health data is stored in compliance with GDPR and KVKK requirements, with restricted access to authorized personnel only. However, no online transmission is 100% secure, and we cannot guarantee absolute security.

12. Third-Party Links

Our Website may contain links to third-party websites, such as social media platforms or medical service providers. We are not responsible for their privacy practices. Please review their policies before providing personal data.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. The updated policy will be posted on this page with a revised "Last Updated" date. We encourage you to review it periodically.

14. Contact Us

If you have questions, concerns, or wish to exercise your data protection rights, please contact us: