Privacy Policy

1. Introduction

DEEPPLANE™ is operated by Healthgov OÜ ("we," "our," or "us"), a company registered in Estonia (Registry Code: 16656270). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website deepplane.com (the "Site") and use our services.

By accessing or using our Site, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Site.

2. Data Controller

The data controller responsible for your personal data is:

• Company Name: Healthgov OÜ
• Trade Name: DEEPPLANE™
• Registry Code: 16656270
• Address: Valge tn 13, Tallinn 11415, Estonia
• Email: Contact Us

3. Information We Collect

3.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Create an account or profile
• Submit a contact form or patient inquiry
• Subscribe to our newsletter
• Submit a patient inquiry to a surgeon
• Leave a review or comment
• Claim a surgeon profile
• Purchase a subscription plan

This information may include your name, email address, phone number, and any other information you choose to provide.

3.2 Patient Inquiry Data

When you submit a patient inquiry through our platform, we collect the information needed to connect you with surgeons, including your name, contact details, photographs and details about your inquiry. Until a surgeon unlocks the inquiry, surgeons see it in reduced form: a summary of your case and a low-resolution, watermarked preview of your photographs, without your full name or contact details. Your full contact details and full-resolution photographs become visible to a surgeon only when that surgeon uses inquiry credits to unlock the inquiry.

The inquiry includes health information: your answers about your health and medical history (for example conditions, smoking, height and weight, earlier procedures), your age and the photographs you upload. This is special-category data under Article 9 of the GDPR. We process it only on your explicit consent, which you give by ticking the consent box on the inquiry form (see section 5.1).

3.3 Healthcare Professional Information

We collect and display information about healthcare professionals (surgeons) from publicly available sources, including but not limited to:

• Professional medical directories and registries
• Hospital and clinic websites
• Medical board certifications
• Professional social media profiles
• Published medical literature and conference presentations

Healthcare professionals may claim their profiles and update their information directly. We provide a mechanism for professionals to request removal of their information (see Section 8).

If you connect a calendar to your panel, you give us a private calendar link (from Google, Outlook, Apple or any other calendar that offers one). We store that link encrypted and read it every three hours. From each entry we use only when it starts and ends and whether it is marked busy. A link that carries more (a Google or Apple link does) reaches our server, but its title, description, place and guests are discarded as the calendar is read and are never stored or logged. From the calendar we store one fact per day, from tomorrow up to six months ahead: whether the day is open. We also keep the link's host name, your time zone, when we last read it, the last error code, and counts of open days, busy days and entries. We do not keep which days are busy, or any entry. If the calendar cannot be read for 48 hours, those days stop being shown to patients. Disconnecting deletes the link and every day read from it, and restores the days you had marked yourself.

3.4 Payment Information

Payment processing is handled by our third-party payment processor, Stripe. We do not store your full credit card details on our servers. Stripe captures and stores your card number on PCI-compliant infrastructure; we receive only a tokenised reference and the last 4 digits. Stripe's privacy policy governs the handling of your payment data.

3.5 Voice Recordings (Phone Line)

If you call our voicemail line, your call is recorded by our telephony provider Twilio and held on Twilio's infrastructure. We download the recording, ask Google Gemini to transcribe and translate it (see Section 4A), and email the transcript + recording link to our admin team for response. Voicemail recordings + transcripts are retained for up to 12 months and then deleted, unless a longer retention is required to resolve a specific support case.

One-time codes and notices about your request by text message

When you ask for a one-time code on your request page, we send it by SMS to the phone number on that request through our telephony provider Twilio (Twilio Verify). The message contains the code and nothing about your request. To limit abuse we keep a keyed hash of the number, its first three and last four characters, the delivery outcome and Twilio's message ID. If you agreed on the request form that DEEPPLANE™ may message you by SMS about your request, we may also send you a short text about that request, for example that a written offer is waiting on your request page, with a link to that page. That text does not name a surgeon, a procedure or a price, and we keep the number, the sending outcome and Twilio's message ID so that we do not send the same notice again for that request. Reply STOP to that text to stop further texts. The number is not used for marketing, and your consent to receive text messages is not shared with third parties. Standard message rates may apply.

3.6 Automatically Collected Information

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

• IP address and approximate location
• Browser type and version
• Device type and operating system
• Pages visited and time spent on pages
• Referring website or source

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Facilitate patient inquiries and connect patients with surgeons
• Process surgeon wallet top-ups, unlock charges, refunds, and account management
• Send transactional notifications (new inquiry alerts, tier-change notifications, refund confirmations) and, with your consent, newsletters or product announcements
• Transcribe and translate voicemail recordings left on our phone line
• Respond to your comments, questions, and requests
• Monitor and analyze usage patterns and trends
• Detect, prevent, and address technical issues + abuse (rate limits, fraud signals)
• Comply with legal obligations

4A. AI-Assisted Content Generation

DEEPPLANE™ uses artificial intelligence (AI) technology to assist in generating informational content about surgeons and procedures. This includes:

• Surgeon Profile Content: AI-generated biographical summaries, surgical methodology descriptions, and FAQ sections based on publicly available data (Google Business profiles, medical registries, professional society memberships)
• Educational Content: AI-assisted medical articles reviewed by board-certified plastic surgeons on our editorial board
• Data Synthesis: AI processing of Google reviews to identify themes and language patterns

All AI-generated content uses hedged language for unverified claims and undergoes quality validation against 23 editorial rules before publication. AI-generated content is clearly attributed and dated. See our Methodology page for details.

4B. Surgeons Listed from Public Sources (GDPR Article 14)

This section is for surgeons whose profile we published before they contacted us. Because we did not collect this information from you, Article 14 of the GDPR requires us to tell you what we hold, where it came from and what you can do about it.

What we hold: professional information that you or your practice have made public: your name and title, specialty, practice name, city, country and address, website, the practice telephone, WhatsApp, email and Instagram account published for patients, your profile photograph, professional registration and board-certification details, published research, and the rating and review count of your Google Business Profile. Some of this appears on your public profile; the contact details we use to reach you are not necessarily shown there.

Where it came from: your own practice website, your Google Business Profile (through Google Places), your public Instagram profile, public professional registers such as the US NPI Registry, PubMed, and other public web pages that list your practice.

Why, and on what legal basis: to let patients find surgeons who perform deep-plane facelifts and check what is and is not verified about them, and to tell you that your profile exists. The legal basis is our legitimate interest in running an independent directory that patients can check (GDPR Art. 6(1)(f)). We use only professional information that has been made public, and you can object at any time.

If we contact you: we may write to the practice email address, WhatsApp number or Instagram account that has been published, to tell you that your profile exists and invite you to claim it. Each invitation to claim your profile also tells you how to ask us to remove it instead. To stop hearing from us without removing the profile, write to hello@deepplane.com.

If you ask for removal: start at Remove my listing. Nothing is taken down on a request alone. We send a confirmation code or link to the email address on your listing (for a claimed profile, the account's sign-in address); where we hold no address but your listing names a practice website, we send it to an address you give us on that website's domain; otherwise a person checks the request. Once it is confirmed, the profile goes offline and we email a link that undoes the removal for 48 hours. After that we ask search engines to drop the page, add your listing to a blocklist so that we do not list you again, and erase the profile's contents: we keep only the listing's internal identifier, its web address and a few status fields, which the blocklist needs, and the record of your request. An encrypted copy of the erased data is kept for 30 days in case the request was not yours, then destroyed.

Your other rights: you can ask for a copy of what we hold about you (Art. 15), have anything wrong corrected, either by claiming your profile and editing it or by writing to us (Art. 16), ask for erasure (Art. 17), and object to the processing (Art. 21), by writing to hello@deepplane.com or through the contact form. You can also complain to the supervisory authority named in section 5.3.

5. Legal Basis for Processing

5.1 Under GDPR (General Data Protection Regulation)

As a company registered in Estonia (an EU member state), we are fully subject to the General Data Protection Regulation (EU) 2016/679 (GDPR). We process your personal data based on the following legal bases:

• Consent (Article 6(1)(a)): Where you have given us explicit consent for specific processing activities, such as marketing communications
• Contract Performance (Article 6(1)(b)): Where processing is necessary to perform a contract with you or to take pre-contractual steps at your request, including subscription services and patient inquiry facilitation
• Legal Obligation (Article 6(1)(c)): Where processing is necessary to comply with EU or Estonian law
• Legitimate Interests (Article 6(1)(f)): Where processing is necessary for our legitimate business interests, provided it does not override your fundamental rights and freedoms
• Explicit consent for health data (Article 9(2)(a)): the health information and photographs in a patient inquiry are special-category data. We process them only on your explicit consent, given by ticking the consent box on the inquiry form, which also covers showing the request to surgeons, including surgeons abroad, and being messaged by SMS, WhatsApp or email about it. You can withdraw your consent at any time through the data-request page (section 8); withdrawal does not affect processing that happened before it, and we then stop processing the data.

5.2 Your GDPR Rights

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

• Right of Access (Article 15): Request a copy of your personal data we hold
• Right to Rectification (Article 16): Request correction of inaccurate or incomplete data
• Right to Erasure (Article 17): Request deletion of your personal data ("right to be forgotten")
• Right to Restriction (Article 18): Request restriction of processing in certain circumstances
• Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format
• Right to Object (Article 21): Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent (Article 7): Withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at Contact Us. We will respond to your request within 30 days.

5.3 Supervisory Authority

As we are established in Estonia, our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). You have the right to lodge a complaint with this authority or with the supervisory authority in your EU member state of residence.

• Estonian Data Protection Inspectorate
• Website: www.aki.ee
• Email: info@aki.ee
• Address: Tatari 39, 10134 Tallinn, Estonia

6. Information Sharing and Disclosure

We may share your information in the following situations:

• With Healthcare Professionals: When you submit a patient inquiry, surgeons in the locations relevant to your request — including surgeons who are not yet registered with DEEPPLANE™ — may be shown a summary of your case and a low-resolution, watermarked preview of your photos, without your full name or contact details, so that they can see the case and respond. Your full name, WhatsApp number, email, message and full-resolution photos are shared only with a verified, registered surgeon once that surgeon unlocks the inquiry, which the surgeon pays for from a prepaid wallet. Your photos are never published on a public page, never used in advertising to the general public, and never shown with your full name.
• Payment Processor (Stripe): Used for surgeon wallet top-ups + auto-reload + refunds. We send Stripe the customer ID, amount, and currency; Stripe handles card data directly.
• Email Delivery (Resend): Used for transactional and notification emails (new-inquiry alerts, tier-change notifications, refund confirmations, password resets). We send Resend the recipient address, subject, and HTML body.
• SMS, WhatsApp and telephony (Twilio): we send Twilio your mobile number and the text of a message when we write to you by WhatsApp or SMS about your request (only if you agreed to this on the inquiry form, or in reply to a message you sent us), when you ask for a one-time code, and for the recordings of our voicemail line. The messages and recordings travel through Twilio’s infrastructure under its data-processing terms.
• AI Processing — Anthropic (Claude): We send the free-text description of your case, together with your first name, country and age, so that a surgeon who does not read your language can be shown a translation and a suggested reply draft. We also send surgeon profile information drawn from public sources, and before/after images published on surgeon profiles in order to estimate the age range and gender shown. Your surname, email address, phone number, WhatsApp number and the health-history fields of your enquiry are not sent.
• AI Processing — Google (Gemini): We send your uploaded photograph once, at the moment you submit it, to detect images that are not genuine patient photographs; the text of any review you choose to publish, together with the surgeon's name and your rating, for moderation; and, if you leave a message on our telephone line, the recording, to produce a transcript. For surgeons and clinic claimants we also send uploaded credential documents, profile photographs, the identity document and selfie submitted to prove a claim, and the text of email replies sent to us.
• AI Processing, fallback providers (NVIDIA, Google Gemini): when Anthropic is unavailable (for example its usage limit is reached), the same request that is described under Anthropic above, the free-text description of your case with your first name, country and age for translation and a suggested reply draft, may be sent instead to NVIDIA (its hosted model API, United States) or to Google (Gemini). Your surname, email address, phone number and the health-history fields of your enquiry are not sent to them either.
• Automated screening and international transfer: The photograph check described above runs automatically. Where it identifies an image as not a genuine patient photograph with high confidence, the enquiry is not passed on to surgeons; if that happens to you, you can ask for the decision to be reviewed by a person by writing to hello@deepplane.com. Anthropic, Google and NVIDIA are established outside the European Economic Area and your data may be processed there; section 10 states the basis for that transfer and what is not yet in place.
• Hosting, storage and CDN (Hetzner, Amazon Web Services, Cloudflare): our servers and database run at Hetzner in Germany. Patient photographs are stored, encrypted, in Amazon Web Services S3 in Frankfurt (eu-central-1), and a surgeon sees them only through short-lived signed links. Cloudflare provides the HTTP edge cache and DDoS protection. Standard request logs (IP address, URL, user agent) flow through these providers.
• Analytics + SEO (Google Search Console, Moz): Aggregated, non-PII data only — backlink graphs, keyword rankings, indexing status. No individual user is identifiable.
• Analytics and error monitoring (Google Analytics 4, Plausible, Sentry): Google Analytics 4 (Google, United States) loads only after you accept analytics cookies in our cookie banner. Plausible Analytics is cookieless and loads without a cookie choice. Neither loads for visitors from Turkey. Sentry, an error-monitoring service used with an EU-region account, receives technical details when the site fails (the page, your browser and your IP address) and records some visits, and every visit that hits an error, as a session replay in which all text and media are masked. Their use is described further in our Cookie Policy.
• Legal Requirements: We may disclose information if required by law or in response to valid legal requests from Estonian or EU authorities
• Business Transfers: In connection with any merger, sale, or acquisition of our business

We share your details with the verified surgeons who access them to offer a consultation; we do not share your information with advertisers, data brokers, or insurers.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure servers, and access controls. However, no method of transmission over the Internet or electronic storage is 100% secure.

8. Your Rights and Choices

8.1 Exercising Your GDPR Rights

As detailed in Section 5.2, you have comprehensive rights under GDPR. To exercise these rights:

• Email us: Send your request to Contact Us
• Use our Data Request form: Visit our Data Removal Request page
• Response time: We will respond within 30 days of receiving your request
• Verification: We may need to verify your identity before processing your request
• Free of charge: Exercising your rights is free, except for manifestly unfounded or excessive requests

8.2 For Healthcare Professionals

If you are a healthcare professional listed on our Site and wish to:

• Claim your profile: Visit Claim Profile to verify and manage your listing
• Update your information: Contact us or use the claim process to update your profile
• Request removal: Submit a removal request via our Data Removal Request page or email Contact Us

We will process removal requests within 30 days. Note that we may retain certain information as required by law or for legitimate business purposes.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities. For more information, please see our Cookie Policy.

10. International Data Transfers

Your information may be transferred to and processed in countries other than Estonia, including countries outside the European Economic Area (EEA). Section 6 says where each provider processes it: our servers are in Germany and our photograph storage is in Frankfurt, both inside the EEA, while Anthropic, NVIDIA, Google, Twilio, Resend, Stripe, Cloudflare, Plausible and Sentry may process it in the United States or other countries outside the EEA.

Our service providers. For these providers we rely on the Standard Contractual Clauses (European Commission Decision 2021/914) in their standard data-processing terms, where they offer them. We have not yet published a provider-by-provider record of which terms apply to each, and we do not claim a specific safeguard for any single provider here beyond that.

Surgeons who receive your request. The surgeons you choose to show your request to are independent professionals, and some practise in countries that have no EU adequacy decision, such as Turkey. We send them your request only on your explicit consent (the consent box on the inquiry form; GDPR Article 49(1)(a)). You should know the risk: in such a country, data protection law may not give you the level of protection or the means of enforcement you have in the EU, and we have not yet put standard contractual clauses in place with the individual surgeons who receive requests. You can withdraw your consent at any time, but that cannot undo a transfer that has already happened.

11. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining the retention period, we consider the nature and sensitivity of the data, potential risks, and legal requirements.

Photographs submitted with a patient inquiry are kept for up to 12 months from submission — or for as long as a surgeon who has taken your case is working from them — and are then deleted. You can ask us to delete them sooner at any time.

The rest of a patient inquiry (your name, contact details and health information) is deleted or anonymised 12 months after you send the request, the same period as the photographs. The period is extended only while a surgeon who took your case is still working from it (a surgeon opened it within the last 12 months), while you have a newer request on file, or while a booking deposit, fee or frozen record ties it to an invoice we must keep. Payment and invoice records are kept for seven years, as Estonian accounting law requires. You can ask us to delete your data sooner at any time.

12. Children's Privacy

Our Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at Contact Us.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

Notice for people in Turkey (Law No. 6698, KVKK)

This notice is also available in Turkish: KVKK Aydınlatma Metni.

This notice is given under Article 10 of Turkey’s Law No. 6698 on the Protection of Personal Data (KVKK) to people in Turkey whose personal data DEEPPLANE™ processes.

Data controller: Healthgov OÜ (DEEPPLANE™), registry code 16656270, Valge tn 13, Tallinn 11415, Estonia. Contact: hello@deepplane.com.

Patients living in Turkey: we do not currently accept requests from patients living in Turkey, apart from one narrow exception for a day-hold link from your own surgeon (next paragraph). A request whose stated country is Turkey, whose mobile number is a +90 number, that is sent from Turkey, or that is sent from a device set to Turkey’s time zone is refused, and no personal data from it is stored. The one thing we keep is an anonymous counter row for each refusal: which entry point refused it, which signal triggered the refusal (time zone, country, number prefix or the reader’s country), a random identifier and the date. It holds no name, number, address, IP address or token, so it cannot identify you. A request sent before this rule is not deleted automatically; you can ask us to delete it by writing to hello@deepplane.com.

The one exception, a day-hold link from your own surgeon: a surgeon may send their own patient a link to hold a surgery date, and the number the surgeon types may be a +90 number. Until you answer, we hold only that number and the details of the hold. Your page first asks where you live. If you answer that you live outside Turkey, and your device’s time zone and connection are not in Turkey, you may give your name and email and your consent, and we then store them. If you answer “In Turkey”, or the time zone or connection is in Turkey, no name or email is stored; if you confirm “In Turkey”, the day goes back to the surgeon at once and we try to delete the number at once; the deletion is refused only if a payment, a checkout or a recovery record already names the row, and then the hourly sweep removes the row thirteen days after it was created (a hold lasts 72 hours and may be extended once by another 72 hours, plus seven days), unless a payment, a checkout or a recovery record names it.

Patients living outside Turkey: a request you send from outside Turkey may be shown to surgeons in Turkey if you select a location there. What is shown, to whom and on what consent is described in sections 3, 5 and 10.

Data we process:

• Visitors from Turkey: the country derived from your IP address (to apply content rules), browser and device information, your cookie choices and, to the extent you allow it, analytics data; and what you send us through the contact form.
• Physicians practising in Turkey: publicly available professional information (name, title, specialty, clinic name and address, website, professional registration details); for physicians who open an account, account and contact details, payment and billing records, and records of panel use.

Purposes: to provide the surgeon directory and its verification information; to manage accounts and provide the service; to answer requests and correspondence; to process payments; to keep the service secure and prevent abuse; and to meet legal obligations.

Legal bases (KVKK Art. 5): the conclusion or performance of a contract; a legal obligation of the controller; data made public by the data subject (physicians’ public professional information); our legitimate interest, provided it does not harm your fundamental rights and freedoms; and your explicit consent for non-essential cookies and analytics.

Transfers (KVKK Arts. 8 and 9): the controller is established in Estonia, and personal data is processed outside Turkey, in the European Union and in the countries where our service providers operate (section 6 lists them). Data may be transferred to providers of hosting and storage, email, messaging, payment, content delivery, analytics, error monitoring and AI-processing services; to surgeons, as regards patient requests; to people using our site, as regards physician profiles; and to authorities entitled by law. For patients, the transfer of a request to surgeons rests on the explicit consent given on the inquiry form. We do not claim here that a transfer undertaking or a standard contract has been filed with the Turkish Personal Data Protection Authority.

Physicians listed without their agreement: you can ask for your profile to be removed, and so object to the processing, at Remove my listing. Once the request is confirmed your profile goes offline; after a 48-hour window in which you can restore it, it is removed from search engines and added to a list that stops it being listed again. Section 4B describes the steps.

Your rights (KVKK Art. 11): to learn whether your personal data is processed; to request information about it; to learn the purpose of processing and whether it is used accordingly; to know the third parties it is transferred to in Turkey or abroad; to ask for its correction if incomplete or inaccurate; to ask for its erasure or destruction under KVKK Art. 7; to ask that such correction or erasure be notified to those it was transferred to; to object to an outcome against you arising solely from automated analysis; and to claim compensation for damage caused by unlawful processing.

How to apply: write to hello@deepplane.com or use the contact form. We answer free of charge within thirty days at the latest (KVKK Art. 13). If you are not satisfied with our answer, you may complain to Turkey’s Personal Data Protection Board (KVKK Art. 14).

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

For data protection inquiries under GDPR, you may contact the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local data protection authority in the EU.