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Privacy Policy

Privacy Policy

Updated 28 October 2020

This Privacy Policy (the “Policy”) applies between you, the user of our mobile application and platform and The Fertility Circle Group Ltd, the owner and provider of the mobile application and online platform. 

At Fertility Circle we believe that technology represents an opportunity to empower people through information and education and, ultimately, allow them to optimise their fertility. With this comes great responsibility to safeguard sensitive information. We take this very seriously and are committed to protecting and respecting your privacy. Please read the following Policy carefully as it contains important information about what personal data we collect, what we do with your personal data, and who we may share your information with.

This Policy should be read alongside, and in addition to, our Terms & Conditions, which can be found here.

 

1.  Definitions and interpretation

Data

collectively all information that you submit The Fertility Circle Group Ltd via the App. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies

a small text file placed on your computer by the App when you visit certain parts of the App and/or when you use certain features;

Data Protection Laws

any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR

the General Data Protection Regulation (EU) 2016/679;

The Fertility Circle Group Ltd

Fertility Circle, we or us

The Fertility Circle Group Ltd, a company incorporated in England and Wales with registered number 12334967 whose registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ; 

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you

any third party that accesses the App and is not either (i) employed by Fertility Circle and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Fertility Circle and accessing the App in connection with the provision of such services; and

App

the mobile application and online platform, and any sub-domains, unless expressly excluded by their own terms & conditions

 

In this Policy, unless the context requires a different interpretation: 

  1. the singular includes the plural and vice versa; 
  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Policy; 
  3. a reference to a person includes firms, companies, government entities, trusts and partnerships; "including" is understood to mean "including without limitation"; 
  4. reference to any statutory provision includes any modification or amendment of it; 
  5. the headings and sub-headings do not form part of this Policy.

Scope of this privacy policy

This Policy applies only to the actions of Fertility Circle and Users with respect to the App. It does not extend to any websites that can be accessed from the App including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Fertility Circle is the "data controller". This means that Fertility Circle determines the purposes for which, and the manner in which, your Data is processed.

2.  Information we may collect from you

  1. Registration and Profile Information.  Access to some parts of the App requires registration and is granted via your email address or your login credentials to social networks (including Facebook and Apple). We will collect information such as name, email address and other optional profile details (such as, a photo) provided at the time of registering to use the App, updating your profile, subscribing to certain services, posting material or requesting further services.

  2. Correspondence. Records of any correspondence with us if you contact us.

  3. Event and Usage Data. In order to improve our service, we automatically record details of your visits to the App including, but not limited to, IP address, device identifier, browser type and operating system information, the referring domain, pages visited, access times, traffic data, location data, and other communication data.

  4. Marketing and Communications Data. We also collect information on your preferences in receiving marketing from us and your communication preferences.

  5. Behavioural Data. We collect behavioural information, which is inferred or assumed information relating to your behaviour and interests, based on your App activity. We organise this into groups, for example,, women who are interested in endometriosis or users interested in male fertility.

  6. Content. You can post content on the App and/or participate in chats through it. This content may contain personal data, but only what you choose to disclose.

  7. Other Information. Any other information you choose to share with us by completing surveys or questionnaires, engaging with our Resident Experts, and or attending events.

  8. Aggregated Data. We also collect, use and share data that we aggregate, such as statistical or demographic data for any purpose, which does not reveal your identity.

  9. Geolocation Information. If you allow us to do so, we may collect your device's geolocation data and save your device's coordinates to offer certain features to you (such as, finding events or directory services nearby). We may also use your device's geolocation information to personalise the App and improve the services we offer you.

3. Use of your personal data

We will only use your personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will update this Policy.

We collect information about you for the following purposes:

  1. To ensure that the App operates in the most effective way for you
  2. To allow you to participate in any interactive features of our App should you decide to do so
  3. To signpost you to or provide you with any information or services that you request from us or we feel may interest you
  4. To operate and improve the app
  5. To carry out any other legitimate interests in delivering our App assuming that your interests and fundamental rights do not override those interests
  6. To carry out any obligations arising under any contracts between us (if applicable)
  7. To notify you about any changes to our App or service, which may affect you
  8. To perform actions for which we have specific consent, such as direct marketing 

Where personal data required for the purposes of delivering our services is not provided, we may not be able to provide you with full access to or functionalities in relation to the App. 

4. Disclosure of your information

We will not disclose your information, except in these limited circumstances:

  1. To service providers or professional advisors for the purposes of providing services such as IT and system administration functions, lawyers, accountants, auditors, insurers and other advisors.
  2. To regulators and Public Authorities, both within and outside your country of residence, where required by law. This includes in order to comply with a law or regulation, a judicial proceeding, court order, or legal request, to protect the safety of any person, or to address fraud or security issues.
  3. In the event of an acquisition or business transfers of Fertility Circle or any of its assets by a third party.
  4. To business partners, where you have expressly chosen to do so, we may share information with business partners for the purposes of providing services to you.

Any third parties described above will be bound by these contractual provisions. Third parties will only have access to personal data for the purposes described and not for any other purposes. Any third parties must process the data in accordance with this Privacy Policy and as permitted by the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

5. Storing your personal data

We have adopted the technical and organisational measures necessary to ensure the security of the personal data we collect and prevent the unauthorised processing or access, loss or alteration of this data. However, no security system is risk free and we cannot guarantee the security of our database.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: abi@thefertilitycircle.com.

We limit access to your personal data to those employees and businesses that require access to such data for the performance of their duties.

The data that we collect from you may be transferred to, processed and stored at a destination outside the European Economic Area. By submitting your data, you agree to this transfer, processing and storage. We will take all steps to ensure that your data is treated securely and in accordance with this Policy.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

6.  Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

7. Your rights relating to your personal data

You have the following rights in relation to your Data: 

  1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why. 
  2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete. 
  3. Right to erase - the right to request that we delete or remove your Data from our systems. 
  4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it. 
  5. Right to data portability - the right to request that we move, copy or transfer your Data. 
  6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: abi@thefertilitycircle.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

8.  Links to other websites

The App may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

9. Cookies

We may use Cookies to improve the way the App works and to monitor how people use our App. Fertility Circle has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law. 

How to reject cookies

If you do not wish to receive cookies, you can typically remove or reject cookies (in full or in part) via your browser settings. In order to do this, follow the instructions provided by your browser (check the Help menu in most browsers). Note that most web browsers are set to accept cookies unless you change your settings.

If you do not accept our cookies, you may not be able to use our App features in full and may experience some inconvenience and/or disruption to your App services.

More information on cookies

For further information about cookies and how to disable them, please refer to https://aboutcookies.org/ or the Information Commissioner’s website:  https://ico.org.uk/your-data-matters/online/cookies/.

10. General

You may not transfer any of your rights under this Policy to any other person. We may transfer our rights under this Policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts. 

11. Changes to this privacy policy

Fertility Circle reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted here and you are deemed to have accepted the terms of the Policy on your first use of the App following the alterations. 

12. Contact

If you have any questions about this Policy or any require any further information, please email us at hello@thefertilitycircle.com 

The Fertility Circle Group Ltd is the controller of your personal data, and is registered in the United Kingdom under company number 12334967. Our registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

 

This Policy was last updated on: 28 October 2020.