Clear Graft

Privacy Policy

Last updated: 15 June 2026

1. Introduction

Welcome to ClearGraft (“we”, “us”, or “our”). ClearGraft is an independent hair transplant comparison platform that connects users with vetted hair transplant clinics and surgeons in the United Kingdom and internationally.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website at https://www.cleargraft.com (the “Website”) and use our services.

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using our Website and submitting an enquiry, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use our Website.

2. Data Controller

ClearGraft operates this Website. For the purposes of UK GDPR, we are the Data Controller responsible for your personal data.

If you have any questions about this Privacy Policy or how we handle your data, please contact us at:

3. Information We Collect

3.1 Personal Information You Provide

When you submit an enquiry through our assessment form, we collect:

  • Full name
  • Email address
  • Phone number
  • Country of residence
  • Age range
  • Preferred contact time
  • Travel preferences (willingness to travel abroad for treatment)
  • Treatment timeline (when you are looking to have treatment)
  • Budget range for treatment

3.2 Special Category (Health) Data

The following information is classed as special category data under UK GDPR because it relates to your health. We only collect this with your explicit consent.

  • Description of your hair loss (type, pattern, and extent)
  • Whether you have had a previous hair transplant procedure
  • Whether you are currently using finasteride or minoxidil
  • Photographs of your hair loss area (optional, where you choose to upload them)

This health information is collected solely for the purpose of matching you with the most suitable clinics and surgeons based on your specific situation. It is shared with clinics only to the extent necessary to provide this matching service.

3.3 Information Collected Automatically

When you visit our Website, we automatically collect certain technical information, including:

  • IP address
  • Browser type and version
  • Pages visited and time spent on each page
  • Referring website
  • Device type and operating system
  • Location data (derived from IP address)

This information is collected via cookies and analytics tools (see Section 6).

4. How We Use Your Information

We use your personal information for the following purposes:

  • To match you with hair transplant clinics and surgeons suited to your specific needs, budget, and location
  • To share your enquiry details (including health information) with relevant clinics so they can contact you
  • To send you a confirmation email that your enquiry has been received and picked up by a clinic
  • To send clinics lead notifications and booking confirmations
  • To improve and maintain our Website and services
  • To analyse how our Website is used via Google Analytics
  • To show you relevant advertisements on Google and Facebook via remarketing
  • To respond to questions submitted via our contact form
  • To comply with our legal obligations

5. Legal Basis for Processing (UK GDPR)

5.1 Standard Personal Data

We rely on the following legal bases to process your standard personal data:

  • Legitimate interests – to operate our comparison service, connect users with clinics, and improve our Website
  • Contract – to fulfil our matching service when you submit an enquiry
  • Consent – where you have given consent, such as accepting cookies or marketing communications
  • Legal obligation – where we are required to process data to comply with applicable law

5.2 Special Category (Health) Data

For special category health data, we rely on:

  • Explicit consent – you provide clear, informed consent by ticking the consent checkbox on our assessment form before submitting your enquiry

You have the right to withdraw your consent at any time by contacting us at privacy@cleargraft.com. Withdrawing consent will not affect the lawfulness of any processing carried out before withdrawal.

6. Cookies and Tracking Technologies

6.1 Google Analytics

We use Google Analytics to understand how visitors interact with our Website. Google Analytics collects information such as how often users visit, which pages they visit, and which websites they used prior to visiting ours.

For more information on how Google uses this data, visit: https://policies.google.com/privacy

6.2 Remarketing

We use remarketing services to advertise ClearGraft to people who have previously visited our Website. Third-party vendors, including Google and Facebook (Meta), may show our ads across the internet and on the Facebook platform based on your prior visits to our Website.

You can opt out of Google's use of cookies by visiting Google's Ad Settings, and opt out of Facebook's cookies via your Facebook Ad Preferences.

6.3 Managing Cookies

You can control and delete cookies via your browser settings. Note that disabling cookies may affect the functionality of our Website.

7. Sharing Your Information

We share your personal information with the following categories of third parties:

  • Hair transplant clinics and surgeons – your contact details, health information, and enquiry details are shared with matched clinics so they can follow up with you directly
  • Google – for analytics and advertising services
  • Meta (Facebook) – for advertising and remarketing services
  • Resend – our transactional email delivery provider, used to send enquiry confirmations and clinic notifications

We do not sell your personal data to any third party. Data is shared only as described in this policy or where required by law.

Clinics in our network are required to handle your data responsibly and in accordance with their own privacy policies and applicable data protection law. We recommend reviewing the privacy policy of any clinic you proceed with.

8. Photographs

Where you choose to upload a photograph of your hair loss area, this image is treated as special category health data. It is:

  • Stored securely and accessible only to ClearGraft and the clinic(s) your enquiry is matched with
  • Used solely to assist clinics in assessing your suitability and providing accurate information
  • Retained for up to 2 years alongside your enquiry data, after which it is permanently deleted

You may request deletion of your photograph at any time by contacting privacy@cleargraft.com.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected.

  • Enquiry data (including health information and photographs) – up to 2 years
  • Contact form submissions – up to 1 year
  • Analytics data – in accordance with Google Analytics default retention settings

After these periods, your data will be securely deleted or anonymised.

10. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

  • Right of access – to request a copy of the personal data we hold about you
  • Right to rectification – to request correction of inaccurate or incomplete data
  • Right to erasure – to request deletion of your data in certain circumstances
  • Right to restrict processing – to request that we limit how we process your data
  • Right to data portability – to receive your data in a structured, machine-readable format
  • Right to object – to object to processing based on legitimate interests
  • Right to withdraw consent – to withdraw consent for health data processing at any time

To exercise any of these rights, contact us at privacy@cleargraft.com. We will respond within 30 days.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

11. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, or destruction. Given that we process special category health data, we apply additional care to the security of this information.

No method of internet transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

12. International Data Transfers

Some third-party service providers (such as Google and Meta) may process your data outside the United Kingdom. Where this occurs, we ensure appropriate safeguards are in place in accordance with UK GDPR, such as Standard Contractual Clauses or adequacy decisions.

Where you are matched with a clinic based outside the UK (for example, in Turkey), your enquiry data will be shared with that clinic internationally. By submitting an enquiry for international treatment, you consent to this transfer.

13. Third-Party Links

Our Website may contain links to clinic profiles and external websites. This Privacy Policy applies only to our Website. We are not responsible for the privacy practices of third-party websites and encourage you to review their privacy policies independently.

14. Children's Privacy

Our Website and services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has submitted data through our Website, please contact us and we will delete it promptly.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the “Last updated” date at the top of this page. We encourage you to review this policy periodically.

16. Contact Us

For any questions, concerns, or data rights requests regarding this Privacy Policy, please contact us:

We aim to respond to all privacy-related enquiries within 5 business days.