Privacy Policy
APS Gender Care

1. Introduction

APS Gender Care (“APS,” “we,” “us,” or “our”) is a specialist gender-affirming surgical clinic located at Srinagarindra 48, Alley 5, Bangkok 10250, Thailand. We are operated by APS Gender Care Co., Ltd.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our website at apsgendercare.com, submit a consultation request, communicate with our team, or engage with our services.

We are committed to protecting your privacy, particularly given the sensitive nature of the health and identity information you may share with us. This policy has been drafted in accordance with:

• The EU General Data Protection Regulation (GDPR)
• The UK GDPR and Data Protection Act 2018
• The California Consumer Privacy Act (CCPA)
• Thailand’s Personal Data Protection Act (PDPA) B.E. 2562 (2019)
• Australia’s Privacy Act 1988

By using our website or submitting your information to us, you agree to the terms of this Privacy Policy.

2. Data Controller

The data controller responsible for your personal data is:

APS Gender Care
Srinagarindra 48, Alley 5, Bangkok 10250, Thailand
📧 info@apsgendercare.com
📞 +66 (0) 92-295-9794

3. What Personal Data We Collect

3.1 Information You Provide Directly

When you interact with us via our website, consultation form, email, WhatsApp, or other channels, we may collect:

• Contact information: Full name, email address, phone number, country of residence
• Health and medical information: Gender identity, gender dysphoria diagnosis, hormone therapy history, existing medical conditions, blood test results, BMI, surgical history
• Identity documents: Passport details (required for hospital admission)
• Payment information: Deposit and balance payment records (processed via secure third-party payment providers; we do not store full card details)
• Communications: Messages, consultation notes, and correspondence with our team

3.2 Information Collected Automatically

When you visit apsgendercare.com, we may automatically collect:

• IP address and approximate location
• Browser type and device information
• Pages visited, time on site, and referral source
• Cookies and similar tracking technologies (see Section 9)

3.3 Information from Third Parties

We may receive information about you from:

• Referring medical professionals or mental health practitioners
• Psychiatric evaluation providers (for Thai legal requirements)
• Social media platforms (if you contact us via Instagram or WhatsApp)

4. Special Category (Sensitive) Data

The health and gender identity information you share with us constitutes special category personal data under GDPR and equivalent laws. We only process this data:

• With your explicit consent
• Where processing is necessary for the provision of healthcare services
• To comply with legal obligations applicable to medical providers in Thailand

You have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5. How We Use Your Personal Data

We use your personal data for the following purposes:

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

6. How We Share Your Personal Data

We do not sell your personal data. We may share it with:

• Surgical and medical teams involved in your care (surgeons, anesthesiologists, nurses, colorectal specialists)
• Ruamjairak Hospital and partner medical facilities where your surgery or diagnostics take place
• Psychiatric evaluation providers (as required by Thai law)
• Accommodation and transport partners if you have purchased an APS Service Package
• Payment processors for deposit and balance transactions
• IT and website service providers (hosting, email, CRM platforms) bound by data processing agreements
• Legal or regulatory authorities if required by law

All third parties with whom we share data are required to maintain appropriate security and confidentiality standards.

International Transfers

APS operates in Thailand and serves patients globally. Your data may be transferred to and processed in countries outside your country of residence. Where we transfer data from the EU/UK, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable
• Your explicit consent

7. How Long We Keep Your Data

After the applicable retention period, data is securely deleted or anonymized.

8. Your Rights

Depending on your country of residence, you may have the following rights regarding your personal data:

• Right of access – request a copy of the data we hold about you
• Right to rectification – request correction of inaccurate or incomplete data
• Right to erasure – request deletion of your data (subject to legal retention obligations)
• Right to restrict processing – request that we limit how we use your data
• Right to data portability – receive your data in a portable format
• Right to object – object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent – at any time, where processing is based on consent
• CCPA rights (California residents) – right to know, delete, and opt out of sale (we do not sell data)

To exercise any of these rights, please contact us at info@apsgendercare.com. We will respond within 30 days of receiving your request.

If you believe we have not handled your data appropriately, you have the right to lodge a complaint with your local data protection authority (e.g., the ICO in the UK, the relevant EU supervisory authority, or the PDPC in Thailand).

9. Cookies

Our website uses cookies and similar technologies to improve your experience. Cookies we use include:

You can control cookies through your browser settings at any time. Disabling certain cookies may affect website functionality.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted via our website
• Access controls limiting who within APS can view sensitive patient data
• Secure communication channels for sharing medical records
• Regular review of our data protection practices

No method of transmission over the internet is 100% secure. If you have concerns about sharing sensitive information, please contact us directly to discuss secure alternatives.

11. Children’s Privacy

Our services are intended for individuals aged 18 years and older (or 20 years without guardian consent, per Thai law). We do not knowingly collect personal data from children under 18 without verified parental or guardian consent. If you believe a minor has submitted data to us without appropriate consent, please contact us immediately.

12. Links to External Websites

Our website contains links to third-party platforms including Google Maps, Instagram, and WhatsApp. This Privacy Policy does not apply to those platforms. We encourage you to review their respective privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised “Last Updated” date. We encourage you to review this policy periodically.

For material changes, we will notify patients and active consultation enquiries by email.

14. Contact Us

For any privacy-related questions, requests, or concerns, please contact:

APS Gender Care
📧 info@apsgendercare.com
📞 +66 (0) 92-295-9794
📍 Srinagarindra 48, Alley 5, Bangkok 10250, Thailand

This Privacy Policy was prepared for APS Gender Care and reflects the nature of services provided, including the collection of sensitive health and identity data from international patients. It is intended as a strong working foundation and should be reviewed by a qualified legal professional familiar with Thai medical law and the data protection laws of your primary patient markets (EU, UK, US, Australia).