Privacy Policy

Last updated: [June 2026]

This Privacy Notice sets out how we, Infinity Medical Clinics Limited (Company No. 1459153), trading as Berkeley Hair Clinic (“we”, “us”, “our”), collect and process personal information about you when you:

• visit or use our website at berkeleyhairclinic.com;
• submit an enquiry, contact form, callback request or newsletter sign-up;
• book a consultation or appointment with us (including via our online booking provider);
• attend a consultation or receive treatment at one of our clinics;
• create an account and use our mobile application to track your treatment progress.

We are the data controller of the personal information we process and are responsible for ensuring our systems, processes, suppliers and staff comply with UK data protection law (the UK GDPR and the Data Protection Act 2018). If you do not agree with this Notice, you should not submit information to us or use our app. If anything is unclear, or you have any questions, please contact us at info@berkeleyhairclinic.com.

Berkeley Hair Clinic is committed to the highest standards of data privacy and protection.

The personal data we collect and how we use it

The data we collect and how we use it depends on how you interact with us.

Identity and contact information. When you enquire, book a consultation, create an account, or use our app, we collect personal details such as your name, title, date of birth, postal address, email address and telephone number(s), and your account settings and login credentials.

Enquiry, booking and marketing information. When you submit an enquiry or contact form on our website, request a callback, or book an appointment, we collect the details you provide — such as your name, email, phone number, preferred clinic location, preferred callback time, and the content of your message. When you sign up to our newsletter or marketing list, we collect your contact details and your marketing preferences. Appointment bookings may be processed through our third-party online booking provider (see “Sharing your personal data”).

Health and treatment information (special category data). To provide hair restoration consultations and treatment, and to let you track your progress, we collect health-related information including the details you give us about your hair loss and medical history, consultation notes, treatment records, and the progress photographs you capture or upload through the app. This is special category data and is treated with additional safeguards (see “Lawful basis” below).

Photographs. Our app allows you to capture and store progress photographs of your scalp/hairline (for example front, hairline and crown views). These images are stored as part of your record so that you and your clinician can compare results over time. Photographs are health data and are treated confidentially. They are never used for marketing without your separate, explicit consent.

Technical and usage information. When you visit our website or use our app, we automatically collect information about your device and use of the service, which may include IP address, device identifiers, app version, operating system, pages or screens viewed, referral source, length of visit and similar diagnostic data. This is used for security, troubleshooting and improving the service.

Payment information. Where you pay for treatment, payment card data is processed by our payment providers subject to financial transaction regulations. We do not store full card details.

How we use your personal data

We use your personal information to:

• respond to your enquiries, contact forms and callback requests;
• arrange, confirm and manage your consultations and appointments (including via our online booking provider);
• register and manage your account, and provide you with our app and services;
• arrange and deliver consultations, treatment and aftercare;
• enable you to record and review your treatment progress, including your progress photographs;
• manage our relationship with you (for example responding to enquiries, sending appointment information, or asking for feedback);
• maintain accurate medical and clinical records as required by law and regulatory guidance;
• monitor, administer, secure and improve our website, app and services (including troubleshooting, testing, analytics, fraud prevention and information security);
• comply with our legal and regulatory obligations;
• where you have given consent, send you information about our services that may be of interest to you (you can withdraw consent at any time).

Lawful basis for processing

We only process your personal information where we have a lawful basis to do so. Depending on the activity, we rely on:

• Contract — where processing is necessary to provide the services you have requested;
• Legitimate interests — for example to secure, administer and improve our services, where your interests and rights do not override those interests;
• Legal obligation — for example to maintain accurate healthcare records;
• Consent — for optional activities such as marketing.

For special category (health) data, including your progress photographs, we additionally rely on UK GDPR Article 9(2)(h) — processing necessary for the provision of health care or treatment — and, where applicable, your explicit consent under Article 9(2)(a). Health data is treated confidentially and is never used for direct marketing without your separate explicit consent.

Sharing your personal data

We do not sell your personal information. We share it only where necessary:

• with our clinicians and clinical staff involved in your care;
• with our online appointment booking provider to schedule and manage your consultations;
• with third-party service providers who help us run our website, app and business (for example secure hosting, IT, our booking system, analytics, advertising and payment processing) — these providers act on our instructions under contracts that require appropriate security and confidentiality;
• with another legal entity in connection with a business transaction such as a merger, acquisition or reorganisation;
• where we are required to do so by law, regulation, or a valid request from an authority;
• where you have given your consent.

Where service providers process data outside the UK, we ensure appropriate safeguards (such as UK adequacy regulations or standard contractual clauses) are in place.

Information security

We have put in place appropriate technical and organisational measures to protect your personal information — including your progress photographs and health data — from accidental loss, unauthorised access, alteration or disclosure. Please be aware that no transmission over the internet is completely secure; communications over the internet are not secure unless encrypted. We have procedures to deal with any suspected data security breach and will notify you and the relevant regulator where we are legally required to do so.

Data retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, clinical or reporting requirements. Clinical and medical records (including treatment photographs) are retained in line with applicable law and regulatory guidance. Retention periods are subject to periodic review.

Your data protection rights

Under data protection law you have the right to:

• access the personal information we hold about you;
• request rectification of inaccurate or incomplete information;
• request erasure of your personal information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing where we rely on legitimate interests;
• request data portability in certain circumstances;
• withdraw consent at any time where we rely on consent.

You will not normally have to pay a fee. We have one month to respond. To exercise any of these rights, please contact us using the details below. You can also delete your account and associated photographs from within the app, or by contacting us.

Cookies, analytics and advertising

Our website uses cookies and similar technologies to help analyse web traffic, remember your preferences and improve the site. A cookie is a small file placed on your device. We may also use first- and third-party analytics and advertising technologies (for example website analytics tools and social media advertising pixels such as those provided by Meta/Facebook) to understand how our website is used and to measure and deliver relevant marketing. These technologies may collect usage data such as pages viewed, device and browser information and interactions.

You can accept or decline cookies through our cookie banner (where shown) and through your browser settings, though declining may prevent you from using some features. Our app may use similar diagnostic and analytics technologies for performance, security and improvement. For more information about how a specific third-party provider uses data, please refer to that provider’s own privacy policy.

Children

Our services and app are intended for users aged 18 and over. We do not knowingly collect personal information from children.

Linked websites and applications

We are not responsible for the privacy practices of third-party websites or applications you may access through links from our website or app. We recommend you review the privacy policy of any third-party service before using it.

Changes to this Privacy Notice

We may update this Notice from time to time. Where we make substantial changes, we will provide an updated Notice and, where appropriate, notify you by other means.

How to contact us / how to complain

If you have any questions about this Notice or wish to exercise your rights, or if you have a concern about how we use your personal information, please contact us:

Infinity Medical Clinics Limited (trading as Berkeley Hair Clinic) 132 Harley Street, London, W1G 7JX, United Kingdom Email: info@berkeleyhairclinic.com Phone: 020 7088 8447

You also have the right to complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline: 0303 123 1113 Website: https://www.ico.org.uk