SWISS LUXURY CLINIC
Operated by HTClinic AG
TERMS AND CONDITIONS
1. Parties and scope
1.1 The Clinic
These Terms and Conditions of Sale (the “Terms”) govern every engagement with Swiss Luxury
Clinic, operated by HTClinic AG, a Swiss stock corporation with its registered seat at Utoquai 49,
8008 Zurich, Switzerland, Commercial Register No. CH-170.3.034.206-1 (“Swiss Luxury Clinic” or
the “Clinic”).
1.2 The Patient
These Terms apply to every individual who requests a consultation, books a treatment, or receives any service from the Clinic (the “Patient”), whether resident in Switzerland or internationally and whether treatment is performed in Zurich or at a partner operating facility retained by the Clinic.
1.3 Relationship to medical consent
These Terms govern the commercial relationship between the Clinic and the Patient. They are distinct from, and supplement, any procedure-specific or medication-specific informed-consent document. Medical consent documents address clinical risks and treatment authorisation; these Terms address the contractual, financial and legal framework of the engagement.
1.4 Incorporation
These Terms are incorporated into every engagement through:
- acceptance of these Terms and the Privacy Policy by separate, unticked, co-located tick-boxes when submitting a consultation request on swissluxuryclinic.com, with acceptance logged with timestamp;
- express reference to these Terms and the Privacy Policy in each written quotation, with payment of the reservation deposit constituting renewed acceptance; and
- reconfirmation on the pre-operative documentation signed by the Patient prior to any surgical treatment, in which the clauses of primary commercial effect (in particular Sections 4, 5 and 9) are restated for express acknowledgement. Non-surgical engagements are accepted by tick-box acceptance on the website and renewed acceptance at the point of quotation, without further signature.
2. Services offered
2.1 Surgical services
Hair transplantation by Follicular Unit Extraction (FUE), including the Clinic’s proprietary FENDI no-shave technique; beard and eyebrow transplantation; and revision or corrective surgery on prior hair restoration performed elsewhere, subject to clinical assessment.
2.2 Non-surgical and medical services
Medical and aesthetic consultations, trichological consultations, platelet-rich plasma (PRP) injections, and medical therapy consultations and prescriptions, each delivered under the responsibility of a licensed physician. Prescription services are conditional on a procedure-specific informed-consent document for each prescribed medication, including, where applicable, written information on known side-effect profiles.
2.3 Proprietary FENDI designation
FENDI is a proprietary designation used by the Clinic for its no-shave FUE protocol. Internal clinical protocols and proprietary surgical-technique know-how disclosed in the course of consultation or treatment are confidential information of the Clinic (Section 8.4).
2.4 Locations of treatment
Surgical treatments are performed at the Clinic’s Zurich premises and at partner operating facilities retained by the Clinic. Partner operating facilities are venues only. The Patient contracts exclusively with HTClinic AG, and the treating surgeon is engaged by HTClinic AG. The Patient does not enter into any direct contractual relationship with any partner facility. The specific venue for each treatment is confirmed in writing in advance of the scheduled date.
2.5 Patients under the age of majority
The Clinic does not treat Patients under the age of 18. For Patients between the age of 18 and the age of majority in their country of residence, the Clinic may require additional consent from a parent or legal guardian and is entitled to postpone treatment pending such consent. Treatment of Patients of diminished capacity requires the consent of the legal representative in accordance with Article 19c of the Swiss Civil Code.
2.6 No outcome guarantee
The Clinic performs each treatment with the professional care required by the applicable medical standard. The Clinic does not, and cannot, guarantee a specific aesthetic or clinical outcome. Hair restoration results depend on biological factors outside the Clinic’s control — donor density, individual healing response, hormonal and genetic factors, and Patient compliance with aftercare. Suboptimal results that do not reflect a breach of the professional standard of care are not grounds for refund or damages.
3. Consultation, medical visits and quotation
3.1 Initial enquiry
Every engagement begins with an enquiry, which the Clinic responds to by proposing a medical visit (in person, by video conference, or by telephone).
3.2 Medical visits
Medical visits with a treating physician of the Clinic are chargeable services in their own right. Unless explicitly stated as complimentary in writing in advance of the appointment, the standard fee for an in-clinic medical visit is CHF 250 inclusive of Swiss value-added tax, payable on the day of the visit. The medical visit fee covers the physician’s professional time, scalp examination, photographic documentation taken for clinical assessment, and the issuance of a written treatment recommendation where applicable.
The Clinic may at its sole discretion offer complimentary medical visits in connection with specific campaigns, referral programmes, or selected international consultations. Any such waiver is communicated to the Patient in writing prior to the appointment.
3.3 Written quotation
Following the medical visit, where the Patient requests treatment, the Clinic issues a written quotation (the “Quotation”). The Quotation describes the treatment, the price inclusive of any applicable Swiss value-added tax, and the payment schedule. Each Quotation is valid for fourteen (14) months from issuance, after which acceptance constitutes a new offer from the Patient that takes effect upon written confirmation by the Clinic.
3.4 No treatment without Quotation and acceptance
No surgical treatment is booked, and no obligation is undertaken by the Clinic, until the Patient has received a written Quotation, accepted its terms, and paid the reservation deposit set out in Section 4.
4. Fees, payment and reservation deposit
4.1 Prices
All prices in each Quotation are stated in Swiss Francs (CHF) and are inclusive of any applicable Swiss value-added tax. The Clinic maintains per-file documentation of medical indication to support the VAT treatment applied to each treatment.
4.2 Accepted currencies
For the convenience of international Patients, the Clinic may issue invoices and accept payment in Swiss Francs (CHF), Euros (EUR) or United States Dollars (USD). The applicable exchange rate is the rate stated on the Quotation or, failing that, the rate applied by the Clinic’s bank on the day of invoicing.
4.3 Payment methods
The Clinic accepts:
- bank transfer in CHF, EUR or USD;
- major credit cards;
- cash, up to CHF 15,000 per engagement, subject to the Clinic’s anti-money-laundering due diligence obligations.
4.4 Reservation deposit (surgical treatments)
A fixed non-refundable reservation deposit of CHF 1,000 confirms the date of any surgical treatment. The deposit is applied in full to the balance of the treatment price if treatment proceeds. Non-surgical treatments do not require a reservation deposit.
4.5 Payment schedule
The balance of the quoted treatment price is payable no later than the day before the scheduled treatment, by bank transfer received in the Clinic’s account or by credit card on the pre-operative day. The Clinic reserves the right not to commence treatment where the full balance has not been received by the scheduled time.
4.6 Late payment
Sums unpaid at their due date bear interest at the statutory rate of 5 % per annum under Article 104 of the Swiss Code of Obligations, from the due date until full payment, without the need for any reminder.
4.7 Service validity
Treatments and any prepaid services must be utilised within fourteen (14) months of conclusion of the contract. Services not utilised within this period expire without entitlement to refund or compensation, save for any extension expressly granted by the Clinic in writing on documented medical grounds.
5. Rescheduling and cancellation
5.1 Rescheduling by the Patient
The Clinic understands that Patient schedules change and accommodates rescheduling within the following framework, which reflects the Clinic’s reserved operating-theatre capacity, surgical team allocation and the opportunity cost of a short-notice vacant slot:
- the Patient may reschedule a treatment up to three (3) times without charge, provided each request is made at least seven (7) business days before the scheduled date;
- each rescheduling beyond the third, and any rescheduling made less than seven (7) business days before the scheduled date, is subject to a fee equal to twenty per cent (20 %) of the quoted treatment price, payable prior to confirmation of the new date.
5.2 Cancellation by the Patient
The Patient may cancel a surgical treatment at any time prior to commencement; the CHF 1,000 reservation deposit is forfeited. The Clinic does not pursue any further cancellation fee, provided the balance has not yet been paid. Cancellation of a non-surgical treatment does not attract a cancellation fee, save for any rescheduling fee that has already accrued under Section 5.1.
5.3 Non-attendance
A Patient who does not attend on the scheduled date without prior notice is treated as having cancelled. For surgical treatments, the reservation deposit is forfeited. No further fee is charged.
5.4 Rescheduling or cancellation by the Clinic
A Patient who does not attend on the scheduled date without prior notice is treated as having cancelled. For surgical treatments, the reservation deposit is forfeited. No further fee is charged.
5.5 Medical unfitness discovered pre-operatively
The Clinic reserves the right to refuse or postpone treatment where, in the treating physician’s clinical judgement, proceeding would pose an unacceptable medical risk. The reservation deposit is retained in all such cases, as compensation for the operating-theatre capacity, surgical team time, and pre-operative preparation already committed to the scheduled date. Where clinically appropriate, the Clinic will at its discretion offer the Patient a credit equal to the deposit applicable to an alternative service or to a future treatment date for which the Patient becomes medically fit.
5.6 No general withdrawal right
Swiss law does not provide a general right of withdrawal from a services contract concluded at the Clinic’s premises, at a professional consultation, or by remote electronic means in the ordinary course. Where Article 40a of the Swiss Code of Obligations applies (in particular, where the contract was concluded at the Patient’s place of work, at the Patient’s home, on public transport, or on a public road), that statutory right is preserved.
6. Medical assessment, consent and Patient obligations
6.1 Pre-operative assessment
The Clinic conducts a pre-operative medical assessment, which may include a review of medical history, current medications, photographic documentation, and laboratory tests. The Clinic relies on the accuracy and completeness of the information provided by the Patient.
6.2 Patient duty to disclose
The Patient is under a duty to disclose truthfully and completely all medical information reasonably relevant to the treatment, including current medications, chronic conditions, allergies, prior surgical history, smoking and alcohol consumption, and any pregnancy or suspected pregnancy. Failure to disclose material information may result in cancellation of treatment under Section 5.5 and may affect the Clinic’s liability position under Section 9.
6.3 Informed consent
Prior to any surgical procedure, the Patient signs a procedure-specific written informed-consent document. The Clinic does not perform any surgical procedure without this duly executed document. For prescribed medical therapy, the Patient’s informed consent is obtained verbally by the treating physician following a discussion of the indication, dosing, and known side-effect profile, and is recorded in the Patient’s clinical file.
6.4 Aftercare
Following any surgical treatment, the Patient receives written aftercare instructions. Compliance is material to the outcome. Non-compliance may compromise results, may void any discretionary post-treatment support offered by the Clinic (Section 7), and, where it causes or contributes to an unsatisfactory outcome, may constitute Patient fault under Article 44 of the Swiss Code of Obligations.
7. Treatment outcomes and discretionary touch-ups
Where a Patient is dissatisfied with the outcome of a treatment, the Clinic may, at its sole discretion and on a case-by-case basis, offer a touch-up procedure. Where offered, the Clinic does not charge for the surgical execution time of the touch-up; the Patient contributes only the Clinic’s operating costs, covering the operating theatre, surgical consumables, and supporting clinical staff. The precise amount is confirmed in writing in advance of any touch-up. Any such offer is a gesture of the Clinic’s ongoing commitment to Patient care and does not constitute an admission of fault, a warranty, or a contractual entitlement. Any discretionary touch-up is conditional on the Patient having complied with the written aftercare instructions, attended scheduled post-operative follow-up consultations, complied with any prescribed medical therapy, and requested the touch-up within a reasonable time and no later than twenty-four (24) months after the original treatment.
8. Confidentiality of Patient identity
8.1 Clinic policy
As a matter of clinic policy and as a central element of the service offered, Swiss Luxury Clinic does not publish, share, or use Patient photographs, names, or identifying details for marketing, social media, website, testimonial, or any external purpose. Every treatment is performed and retained in strict confidence.
8.2 Clinical records retained
Section 8.1 does not restrict the Clinic’s retention of clinical photographs and records for internal clinical, surgical-planning and medico-legal purposes, in accordance with applicable medical record-keeping law (minimum ten (10) years from the last treatment under the relevant cantonal health legislation).
8.3 Third-party requests
The Clinic does not disclose the existence or content of a Patient’s treatment to any third party except (i) with the Patient’s written authorisation, (ii) where required by compulsory law or final court order, or (iii) to the Clinic’s own professional advisors under duties of confidentiality no less strict than those owed by the Clinic.
8.4 Patient confidentiality obligation
The Patient agrees to treat as confidential, and not to disclose to any third party, trade-secret-quality information disclosed by the Clinic in the course of consultation or treatment — specifically, internal clinical protocols, documented surgical procedural know-how, and specific technical details of the FENDI no-shave technique. This obligation does not restrict the Patient’s right to discuss the Patient’s own experience of treatment, to publish reviews, or to seek independent medical advice.
In keeping with the mutual respect that defines the engagement, the Patient agrees that any public statement made by the Patient about the Clinic, the treating physician, or the clinical staff will be a fair and accurate account of the Patient’s own experience, identifying any subjective views as such. The Patient acknowledges that statements falling materially short of this standard — in particular, statements that are false, that misrepresent the treatment received, or that are made by an individual who has not in fact received the treatment described — may give rise to claims under Swiss law for defamation (Art. 173–174 of the Swiss Penal Code), violation of personality rights (Art. 28 of the Swiss Civil Code), and unfair competition (Art. 3 of the Federal Act against Unfair Competition).
Where the Patient is dissatisfied with any aspect of the engagement, the Clinic invites the Patient to address the matter directly under Section 12 before public commentary.
9. Liability
The Clinic is liable to the Patient in accordance with Swiss law for breach of the professional medical standard of care, including failure to obtain informed consent where required. Liability arises only where the Patient establishes (i) a breach of the applicable professional standard of care, (ii) damage, and (iii) an adequate causal link.
The Clinic is not liable for treatment outcomes that do not reflect a breach of the professional standard of care, including outcomes attributable to the Patient’s biology, healing response, hormonal or genetic factors, or non-compliance with aftercare instructions.
The Clinic maintains professional liability insurance appropriate to its activities, in accordance with Swiss medical practice requirements. Nothing in these Terms excludes or limits the Clinic’s liability for intentional wrongdoing, gross negligence, or any other liability that cannot be excluded or limited under Swiss mandatory law.
10. Force majeure
Neither party is liable for any failure or delay in performing its obligations where the failure or delay results from events beyond its reasonable control, including acts of authority, epidemic, pandemic, war, civil unrest, strike, natural disaster, failure of critical medical equipment, or sudden incapacity of the treating surgeon. Where a force majeure event prevents the Clinic from delivering a scheduled treatment, Section 5.4 applies.
11. Intellectual property
All materials provided by the Clinic in the course of the engagement — including the FENDI protocol description, written aftercare instructions, information brochures, and any other documentation — are the intellectual property of HTClinic AG or its licensors. The Patient receives a personal, non-transferable right to use such materials solely for the purposes of the Patient’s own treatment and recovery, and may not reproduce, adapt, or distribute them.
12. Complaints
A Patient who is dissatisfied with any aspect of the Clinic’s service is invited to address the matter directly to [email protected]. The Clinic acknowledges every complaint within five (5) working days and responds substantively within twenty (20) working days. The parties agree to use reasonable efforts to resolve any dispute amicably and in good faith before initiating formal proceedings.
13. Data protection
In connection with the engagement, the Clinic processes Patient personal data, including categories of sensitive health data: contact and identity details, medical history, clinical data generated during treatment, clinical photographs retained in the medical file, financial data, communications, and website usage data.
The Clinic’s processing of Patient data complies with the Swiss Federal Act on Data Protection (revFADP / nFADP, in force since 1 September 2023) and, where applicable to international Patients, the EU General Data Protection Regulation (GDPR). The Patient’s rights — including rights of access, correction, deletion (subject to the Clinic’s statutory record-keeping obligations), objection, portability, and withdrawal of consent — are exercisable at any time by writing to [email protected].
The complete description of processing purposes, legal bases, service providers, retention periods, international transfers, and Patient rights is set out in the Clinic’s Privacy Policy, available at swissluxuryclinic.com. The Privacy Policy is co-presented with these Terms at the point of acceptance under Section 1.4 and is incorporated into these Terms by reference.
14. General provisions
14.1 Entire agreement
These Terms, together with each Quotation and the procedure-specific or medication-specific informed-consent document, constitute the entire agreement between the Clinic and the Patient for the treatment concerned, and supersede any prior oral or written understanding.
14.2 Amendments
The Clinic may amend these Terms from time to time. Amendments apply to new engagements entered into after publication of the amended Terms. Existing engagements continue to be governed by the Terms in force at the time of deposit payment or, for non-surgical engagements, at the time of the Patient’s written acceptance of the Quotation.
14.3 Severability
If any provision of these Terms is held invalid or unenforceable by a competent court, the remaining provisions continue in full force. The invalid provision is replaced by a valid provision approximating as closely as possible the economic intent of the original.
14.4 Assignment
The Patient may not assign any rights or obligations under these Terms. The Clinic may assign its rights and obligations to an affiliated entity or to a successor in interest in connection with a corporate reorganisation or sale of the business.
14.5 Language
These Terms are published in German, English and (in due course) French. The German version is the legally authoritative version; English and French versions are provided for Patient convenience. In the event of any discrepancy between versions, the German version prevails.
14.6 Governing law
These Terms, and any dispute arising out of or in connection with them, are governed by Swiss substantive law, to the exclusion of its conflict-of-laws rules and of the United Nations Convention on Contracts for the International Sale of Goods.
14.7 Jurisdiction
The ordinary courts of the canton of Zurich have exclusive jurisdiction over any dispute arising out of or in connection with these Terms, subject to the Patient’s right, where the Patient qualifies as a consumer under Article 32 of the Swiss Civil Procedure Code, to sue at the Patient’s Swiss domicile.
SWISS LUXURY CLINIC
Operated by HTClinic AG
PRIVACY POLICY
Datenschutzerklärung
1. Who we are
1.1 Data controller
The data controller for the personal data described in this Privacy Policy is HTClinic AG, a Swiss stock corporation operating under the brand Swiss Luxury Clinic, with its registered seat at Utoquai 49, 8008 Zurich, Switzerland and Commercial Register No. CH-170.3.034.206-1 (referred to in this Policy as “the Clinic”, “we”, “us”, or “our”).
1.2 Medical records
Clinical records (Krankengeschichte) are maintained by HTClinic AG as data controller, under the personal supervision of the treating physician in accordance with the Medical Professions Act (MedBG) and the medical record-keeping requirements of the canton of Zurich. The treating physician is identified to the Patient at the time of consultation.
1.3 Contact for data protection matters
All communications relating to this Privacy Policy and to your data protection rights should be addressed to the Clinic’s designated data protection contact, Dr Alkiviadis Karoutis (Chief Executive Officer and physician), at [email protected]. Appointment of a Data Protection Advisor is not required of private companies under Article 10 of the nFADP, and the Clinic’s processing activities do not meet the threshold for mandatory appointment of a Data Protection Officer under Article 37 of the GDPR. The Clinic has nonetheless designated a single named contact responsible for data protection matters, to ensure that Patient enquiries and rights requests are received and addressed by an identified individual within the Clinic’s leadership.
2. What personal data we process
We process the following categories of personal data:
2.1 Identification and contact data
Name, date of birth, residential address, country of residence, email address, telephone number, and where applicable language preference and salutation. Provided by you when you submit a consultation request, communicate with us, or attend a treatment.
2.2 Clinical and health data
Medical history, current medications, allergies, prior surgical history, smoking and alcohol use, pregnancy status where relevant, scalp examination findings, donor and recipient area assessments, photographic documentation taken for clinical purposes, laboratory test results obtained as part of the pre-operative workup, anaesthesia records, intra-operative observations, post-operative progress notes, and any related clinical correspondence. These data are sensitive personal data within the meaning of Article 5 lit. c nFADP and special category data within the meaning of Article 9 GDPR.
2.3 Financial data
Quotation amounts, invoice records, payment confirmations and method (bank transfer, card or cash), and where applicable currency conversion details. We do not receive or retain full payment-card numbers; card payments are processed by our payment service provider.
2.4 Communications data
Records of correspondence with you across the Clinic’s contact channels — including email, telephone notes, secure messaging, and pre- and post-operative communications — together with metadata such as date, time, and channel.
2.5 Website usage data
When you visit swissluxuryclinic.com, we receive technical data including your IP address (in truncated form for analytics purposes where consent has been given), browser type and version, device type, the pages you visit, and the way you arrived at our site. The full scope of website tracking is described in Section 6.
3. Why we process your data, and the legal basis
We process your personal data for the following purposes, each with a corresponding legal basis under the nFADP and, where relevant, the GDPR:
3.1 Responding to consultation requests and issuing quotations
Legal basis: pre-contractual measures at your request (Art. 31 para. 2 lit. a nFADP; Art. 6(1)(b) GDPR). Without this data we cannot assess your suitability or provide a quotation.
3.2 Providing treatment
Legal basis: performance of the treatment contract (Art. 31 para. 2 lit. a nFADP; Art. 6(1)(b) GDPR). For clinical and health data, processing is also justified by the purposes of preventive medicine, medical diagnosis, the provision of healthcare, and the management of healthcare systems and services (Art. 9(2)(h) GDPR), provided that the relevant cantonal medical confidentiality framework applies.
3.3 Maintaining medical records
Legal basis: legal obligation under cantonal medical legislation and the Medical Professions Act (MedBG), which require physicians to maintain a clinical record for a minimum of ten (10) years (Art. 31 para. 1 lit. c nFADP; Art. 6(1)(c) GDPR).
3.4 Post-operative follow-up communications
Following surgical treatment, patients receive periodic automated follow-up communications over the post-operative period. These messages are part of the clinical follow-up programme and address recovery progress, photographic documentation requests, and continuity of care. Where a treating physician identifies a clinical indication during follow-up review, the Patient may receive a recommendation for further treatment; such recommendations are issued on clinical grounds by a physician and form part of the Patient’s ongoing care, not marketing communications. Legal basis: performance of the treatment contract (Art. 31 para. 2 lit. a nFADP; Art. 6(1)(b) GDPR). You may opt out of the follow-up programme at any time by replying to any follow-up email or writing to [email protected]; opting out does not affect any other aspect of your treatment relationship with the Clinic.
3.5 Newsletter and clinic updates
Where you have separately and explicitly opted in, we send occasional clinic updates by email. Legal basis: your consent (Art. 31 para. 1 nFADP; Art. 6(1)(a) GDPR). Consent is collected through a dedicated, unticked check-box, separate from the acceptance of our Terms and Conditions and this Privacy Policy. You may withdraw your consent at any time using the one-click unsubscribe link in every email or by writing to [email protected].
3.6 Invoicing, accounting and tax compliance
Legal basis: legal obligation under the Swiss Code of Obligations and tax law, including the requirement to retain accounting records for ten (10) years (Art. 31 para. 1 lit. c nFADP; Art. 6(1)(c) GDPR).
3.7 Operating and improving our website
Legal basis: legitimate interest in operating, securing, and improving our website, balanced against your data-protection interests (Art. 31 para. 1 nFADP; Art. 6(1)(f) GDPR), and, for non-essential cookies and tracking, your consent given through our cookie banner (Art. 31 para. 1 nFADP; Art. 6(1)(a) GDPR).
3.8 Defending against and asserting legal claims
Legal basis: legitimate interest in legal protection of the Clinic and, where applicable, legal obligation (Art. 31 para. 1 nFADP; Art. 6(1)(f) and (c) GDPR).
4. Confidentiality of Patient images and identity
As a matter of clinic policy and as a central element of the service we offer, Swiss Luxury Clinic does not publish, share, or use Patient photographs, names, or any identifying details for marketing, social media, website, testimonial, or any other external purpose.
Clinical photographs taken during the course of treatment are retained exclusively in the Patient’s clinical file for surgical-planning, comparative-assessment, and medico-legal purposes. They are never used externally and are never disclosed to any third party except in the limited circumstances set out in Section 5.
This commitment is contractual and is restated in our Terms and Conditions of Sale at Section 8.
5. With whom we share your data
We share your personal data only as necessary to deliver our services and as required by law. The categories of recipient are:
5.1 Treating physicians and clinical team
Surgeons, anaesthetists, nurses, and clinical assistants engaged by HTClinic AG to deliver your treatment. Each is bound by professional medical confidentiality (Art. 321 of the Swiss Penal Code, Berufsgeheimnis) and contractual confidentiality obligations to the Clinic.
5.2 Partner operating facilities
Where your surgical treatment takes place at a partner operating facility retained by the Clinic, the partner facility receives only the operational information necessary to host the treatment (booking date, treatment type, name of the treating surgeon, theatre and equipment requirements). Partner facilities do not receive your clinical history, do not invoice you, and do not become a controller of your data.
5.3 Service providers (data processors)
We engage third-party service providers to deliver specific operational functions. Each is bound by a written data-processing agreement and processes data only on our documented instructions. The principal categories of recipient are:
- a domain registrar based in the European Union, which records the public domain registration of swissluxuryclinic.com;
- a content-delivery and DNS provider operating from EU and United States infrastructure, which proxies website traffic for performance and security;
- Tophost, an EU-based website-hosting provider with infrastructure in Belgium, which hosts the Clinic’s public website;
- an EU/United-States-based email and customer-relationship platform, which supports newsletter and marketing email delivery;
- a productivity and email-delivery suite operated by a US-headquartered provider with EU data residency, used for clinic email correspondence and the post-operative follow-up communications described in Section 8.2;
- a Swiss-based payment processor, which handles card payments for treatments and is certified to PCI DSS Level 1;
- EU-affiliated website-analytics and advertising-measurement providers, see Section 6;
- enterprise artificial-intelligence providers operating under EU/Swiss data residency, see Section 7.
5.4 Professional advisors
Lawyers, auditors, accountants and tax advisors retained by the Clinic, each subject to professional confidentiality obligations no less strict than ours.
5.5 Authorities, where required by law
We disclose data to public authorities, courts, regulators, or law enforcement only where required by Swiss law, by a final court order, or by a binding regulatory request. Where the law permits, we will inform you of such a disclosure.
5.6 No sale of personal data
We do not sell, rent, or trade your personal data to any third party for any purpose.
6. Website tracking and cookies
6.1 What we use
Our website uses the following tracking technologies:
- Strictly necessary cookies — required for the website to function (session management, security, load balancing). These do not require consent.
- Google Tag Manager — a tag-management container that loads other tags on the site according to your cookie preferences. Operated by Google Ireland Limited.
- Google Analytics 4 — visitor analytics, used to understand aggregate website usage and improve our content. IP addresses are truncated. Loaded only with your consent. Operated by Google Ireland Limited.
- Google Ads conversion tag — measures whether visits to our site that originated from a Google Ads click resulted in a consultation request. Loaded only with your consent. Operated by Google Ireland Limited.
6.2 How we obtain and manage consent
On your first visit, our cookie banner asks you to accept or reject non-essential cookies, by category. You can accept all, reject all, or make granular choices. Strictly necessary cookies are loaded regardless because the site cannot function without them; all other tags are loaded only after, and to the extent of, your active opt-in. You can change or withdraw your consent at any time by clicking the cookie preferences link in the website footer.
6.3 Transfers outside Switzerland
Some of the third-party providers used to operate the Clinic’s website operate from EU and United States infrastructure. Personal data may be transferred to the United States by these providers in the course of operating their services. Such transfers rely on (i) Switzerland’s recognition of the Swiss-U.S. Data Privacy Framework as providing adequate protection, in force from 15 September 2024, where the receiving entity is a certified Swiss-U.S. DPF participant, and/or (ii) the European Commission’s standard contractual clauses with Swiss-specific addenda where the receiving entity is not certified under the DPF. The Clinic verifies the certification status of each US-based processor before engagement.
6.4 No Patient health data is shared with advertising platforms
The tracking described in this Section operates on Patient website behaviour only and does not transmit clinical, health, treatment, or contact-form content to advertising platforms. Patient health data is held within the Clinic’s clinical-records environment described in Section 5 and is never integrated with marketing or advertising tooling.
7. Use of artificial intelligence in our operations
Our physicians make every clinical decision and write every treatment recommendation themselves. The Clinic uses enterprise artificial-intelligence tools to support administrative work around clinical activity — such as drafting administrative correspondence and helping physicians polish written proposals from their own consultation notes. The Clinic does not use AI for clinical diagnosis, for solely automated decisions about Patient treatment, or for analysis of Patient clinical photographs.
The AI providers used by the Clinic operate under enterprise-tier terms. Our AI providers do not train their models on the Clinic’s data; this is a contractual term of the enterprise tier we use. All AI tools used by Clinic physicians are accessed only through Clinic-managed workspace accounts, never through personal or consumer accounts. Patients may object to the use of AI in the handling of their engagement at any time by writing to [email protected]; the Clinic will route communications through manual processes only, without affecting the standard of care or the price of treatment.
8. Newsletter and post-operative communications
8.1 Newsletter (consent-based)
If you have actively opted in to receive Clinic updates, we send occasional emails covering topics such as new treatment availability, clinic announcements, and professional content. Each email contains a one-click unsubscribe link. Withdrawing consent for the newsletter does not affect any treatment-related communications you receive as a Patient.
8.2 Post-operative follow-up programme (treatment-based)
Following any surgical treatment, you receive periodic automated follow-up communications over the post-operative period. These messages support clinical continuity of care, document recovery progress, and provide a structured channel for your post-operative questions. They do not contain marketing content. You may opt out of the follow-up programme at any time by replying to any follow-up email with the word “UNSUBSCRIBE” or by writing to [email protected]. Opting out of the follow-up programme does not affect any other aspect of your relationship with the Clinic, and you may opt back in at any time.
9. International transfers of your data
Your clinical records and the systems that hold them are stored exclusively in Switzerland, on infrastructure operated in-house by HTClinic AG. Card payments are processed by a Swiss-based payment processor within Switzerland. The Clinic does not transfer Patient clinical data outside Switzerland in the ordinary course of treatment.
Three categories of operational data may sit on infrastructure outside Switzerland, each disclosed transparently:
- The Clinic’s public website is hosted on EU-based infrastructure and proxied through a third-party content-delivery network for performance and security purposes — see Section 5.3. Website operational data (visitor logs, server logs, form-submission data in transit) is processed on this infrastructure.
- Website analytics, advertising measurement, and email-marketing tooling involve transfers to providers operating from EU and United States infrastructure — see Section 6.3. Enterprise AI services used by the Clinic process data on United States infrastructure under Standard Contractual Clauses — see Section 7.
- Where you, as a Patient, request that we transmit a copy of your medical record to a physician in another country (for example, your local doctor on return home), we make that transfer at your written request and on the legal basis of your consent (Art. 17 nFADP; Art. 49(1)(a) GDPR).
10. How long we keep your data
We retain your personal data only as long as necessary for the purposes described in this Policy or as required by law:
- Clinical records: a minimum of ten (10) years from the date of the last treatment, in accordance with the medical record-keeping requirements of the canton of Zurich. Longer retention may apply where required for medico-legal reasons.
- Financial and accounting records: ten (10) years, in accordance with Article 958f of the Swiss Code of Obligations.
- Lead and consultation data where no treatment results: up to twenty-four (24) months from the last meaningful contact, after which the lead record is deleted unless you have requested earlier deletion or have separately opted in to the newsletter.
- Newsletter subscription data: retained for the duration of your subscription and for a short post-unsubscribe period for audit purposes (typically twelve (12) months), then deleted.
- Website analytics data: aggregated metrics retained per provider settings (typically fourteen (14) months for event-level data).
11. Your rights
Subject to the conditions and limitations set out in the nFADP and, where applicable, the GDPR, you have the following rights in respect of your personal data:
- Right of access — to obtain confirmation of whether we process your data and a copy of that data, together with information about how we process it (Art. 25 nFADP; Art. 15 GDPR).
- Right to rectification — to have inaccurate data corrected (Art. 32 para. 1 nFADP; Art. 16 GDPR).
- Right to erasure — to request deletion of your data, subject to the Clinic’s overriding legal obligations to retain medical and accounting records.
- Right to restriction — to request that processing be limited in defined circumstances (Art. 18 GDPR; equivalent under nFADP).
- Right to object — to processing based on legitimate interests, including a right to object to direct marketing at any time (Art. 30 nFADP; Art. 21 GDPR).
- Right to data portability — to receive certain data you have provided to us in a structured, machine-readable format (Art. 28 nFADP; Art. 20 GDPR).
- Right to withdraw consent — at any time, in respect of processing based on consent, without affecting the lawfulness of processing carried out before withdrawal.
12. How we protect your data
We apply organisational and technical measures appropriate to the sensitivity of the data we process, including: access restriction on a need-to-know basis within the clinical and administrative team; physical security at the Clinic’s premises and clinical records storage; encryption of data in transit and, where applicable, at rest; secure authentication for staff access to electronic clinical and administrative systems; documented confidentiality obligations for all personnel and contractors; and periodic review of our security measures.
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you and the FDPIC in accordance with our obligations under Article 24 of the nFADP and, where applicable, Articles 33 and 34 GDPR.
13. Patients under the age of majority
As stated in our Terms and Conditions, the Clinic does not treat Patients under the age of 18. Accordingly, we do not knowingly collect personal data of any individual under 18 in connection with treatment. Where parental or guardian consent is required for a Patient who has reached 18 but not the age of majority in their country of residence, that consent is collected and recorded separately.
14. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, in our service providers, or in applicable law. The current version is always published at swissluxuryclinic.com with its effective date. Where changes are material, we will inform you by email or by a prominent notice on our website before the changes take effect.
