Effective date: Apr 30, 2026
1. About This Policy
This Privacy Policy explains how BTW Media Corp. ("we," "us," or "our") collects, uses, shares, and protects information about you when you visit https://www.hairtransplant.vn (the "Site") or otherwise interact with our services.
HairTransplant.vn is an information and referral platform. We help users research hair transplant procedures and connect with independent third-party clinics. We are not a medical provider, do not employ clinicians, and do not provide medical services.
2. Who We Are
The operator of this Site and the controller responsible for your personal information is:
BTW Media Corp.
3172 N Rainbow Blvd #45393, Las Vegas, NV 89108
Incorporated in Delaware, USA
Email: legal@hairtransplant.vn
3. Information We Collect
Information you provide
- Consultation and contact details: when you submit a consultation request, contact form, or similar inquiry, we collect information such as your name, email address, phone number, messaging app handle (e.g., WhatsApp), country, photographs you choose to share, and any details you include in your message.
- Account details: if you create an account, we collect login credentials and any profile information you provide.
- Communications: records of correspondence with us.
Information collected automatically
- Device and usage data: IP address, browser type, device identifiers, pages viewed, referring URL, timestamps, and similar log data.
- Cookies and similar technologies: we and our analytics providers use cookies, pixels, and local storage to operate the Site and understand how it is used. See "Cookies and Analytics" below.
4. How We Use Your Information
- To respond to your inquiries and connect you with the clinic(s) you choose.
- To operate, maintain, secure, and improve the Site.
- To send you service-related communications and, where permitted, marketing communications you can opt out of at any time.
- To detect, investigate, and prevent fraud, abuse, and security incidents.
- To comply with legal obligations and enforce our Terms of Service.
5. How We Share Your Information
This is the most important disclosure for users of our service: when you submit a consultation request through HairTransplant.vn, we forward the information you provide to one or more independent third-party clinics. Once a clinic receives your information, that clinic acts as an independent data controller (or business, under US law) and processes your information under its own privacy policy. We do not control how clinics use, store, or share your data after we transmit it to them.
We may also share information with:
- Service providers who process information on our behalf (hosting, email delivery, analytics, customer support, fraud prevention).
- Legal and safety: to comply with law, respond to lawful requests, or protect rights, property, or safety.
- Business transfers: in connection with a merger, acquisition, financing, or sale of assets.
- With your consent or at your direction.
6. Our Business Model and "Sale" of Personal Information
We want to be transparent about how our service works financially. HairTransplant.vn is a lead-generation and referral platform. Clinics may pay us a referral fee, subscription fee, placement fee, or similar consideration in connection with inquiries we forward to them. Because we receive consideration in exchange for transmitting your personal information to clinics, this activity meets the broad definition of a "sale" of personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"), and may constitute a "sale" or "share" under similar laws in other US states.
The categories of personal information involved in this activity include identifiers (name, email, phone), commercial information (the procedure or services you are inquiring about), and any photographs, descriptions, or other content you choose to submit. The clinics that receive this information are the categories of recipients.
You have the right to opt out of this activity. See "Your Privacy Rights" below for how to exercise it. Opting out will mean we cannot forward your inquiry to clinics, which is the core function of the Service — so practically, opting out is equivalent to not submitting a consultation request. If you have already submitted an inquiry, opting out will stop future sharing but cannot recall information already transmitted to a clinic.
Separately, our use of analytics and advertising cookies may also be treated as a "sale" or "share" under CCPA. You can manage these through your browser, any cookie banner shown on the Site, and the opt-out mechanism described below. We do not knowingly sell or share the personal information of consumers under 16 years of age.
7. International Data Transfers
We are based in the United States. Some clinics and service providers we work with are located outside your country, including in Vietnam and other markets. When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been deemed to provide an adequate level of protection, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or equivalent mechanisms.
8. Data Retention
We retain personal information for as long as needed to provide the service, comply with our legal obligations, resolve disputes, and enforce our agreements. Consultation inquiries are typically retained for up to 24 months unless a longer period is required. You may request deletion as described below.
9. Your Privacy Rights
If you are in the European Economic Area, United Kingdom, or Switzerland (GDPR / UK GDPR)
You have the right to access, rectify, erase, restrict, or object to processing of your personal data, the right to data portability, and the right to withdraw consent at any time. Our lawful bases for processing include your consent (e.g., for marketing), performance of a contract or steps prior to entering into one (e.g., forwarding your inquiry to a clinic), our legitimate interests (e.g., operating and securing the Site), and compliance with legal obligations. You also have the right to lodge a complaint with your local data protection authority.
If you are a California resident (CCPA/CPRA)
You have the right to know what personal information we collect, use, and share; the right to request deletion or correction; the right to opt out of the "sale" or "sharing" of personal information (including the lead-forwarding activity described in Section 6); and the right to limit the use of "sensitive personal information." We will not discriminate against you for exercising these rights.
To opt out of the sale or sharing of your personal information, email us at legal@hairtransplant.vn with the subject line "Do Not Sell or Share My Personal Information." If you submit a consultation request after exercising this right, we will treat that submission as your renewed direction to forward the information to the clinic(s) you have selected, and only to those clinics.
How to exercise your rights
Email us at legal@hairtransplant.vn. We may need to verify your identity before fulfilling certain requests. If you authorize an agent to make a request on your behalf, we may require evidence of that authorization.
10. Cookies and Analytics
We use cookies and similar technologies to operate the Site, remember your preferences, and measure how the Site is used. We use Google Analytics and other standard web analytics tools. You can manage cookies through your browser settings and, where available, through any cookie banner shown on the Site. Disabling cookies may affect Site functionality.
11. Security
We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Children's Privacy
HairTransplant.vn is not directed to children under 18, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can delete it.
13. Third-Party Sites and Clinics
The Site may link to third-party websites, including clinic websites. We are not responsible for the privacy practices of those third parties, which are governed by their own policies. Clinics that receive your information through our service are independent of us and operate under their own privacy practices.
14. Changes to This Policy
We may update this Privacy Policy from time to time. We will post any changes on this page and update the effective date above. Material changes will be communicated through the Site or by email where appropriate.
15. Contact
For privacy questions or to exercise your rights, contact:
BTW Media Corp.
Attn: Privacy
3172 N Rainbow Blvd #45393, Las Vegas, NV 89108
Email: legal@hairtransplant.vn