The Fertility Circle Group Ltd
Protected Health Information. Fertility Circle is also committed to protecting the privacy of your protected health information (“Protected Health Information”). “Protected Health Information” is a subset of Personal Information that is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition; related health care services; or related to the past, present, or future payment for the provision of health care to you.
Information That Fertility Circle Collects
Receipt and Collection of Information. We collect Personal Information from users. In each case, you will only be required to provide the Personal Information that we need in order to be able to provide the services you have requested. You may be entitled under data protection laws to access and review the Personal Information that we hold on you, if you provide the necessary consent and background information and pay any mandated fee. All such communications regarding access to your personal data should be addressed to: firstname.lastname@example.org. Such inquiries should clearly be marked as data protection queries and as being time sensitive.
Fertility Circle provides User the option, at User’s sole election, to upload a profile image that is viewable by other participants of the Services, but this is not mandatory. User may delete User’s profile picture at any time by logging into the Mobile App and visiting the profile settings page.
Personal Health Information. Fertility Circle may obtain your personal health information from your health care provider upon User’s request and prior approval. Fertility Circle may collect certain personal health information that is relevant to providing its services, such as fertility and wellbeing information.
Fertility Circle also collects data about User, including about User’s fertility information, health indicators, and related information that does not identify User and that enables User to fully participate in the Service.
Information Fertility Circle Collects or Stores as User Accesses and Uses the Website and Service
In addition to any Personal Information or other information that User choose to submit to Fertility Circle via Fertility Circle’s Website, Fertility Circle and Fertility Circle’s third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever User visits or interacts with the Website (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to User’s personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever User visits or interacts with Fertility Circle’s Website and/or the Mobile App. To the extent Fertility Circle associates Usage Information with User’s Personal Information Fertility Circle collects directly from User on the Website, Fertility Circle will treat it as Personal Information.
This Usage Information may include:
- User’s IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to User’s Device used to access the Website, and Fertility Circle’s computers identify User’s Device by its Device Identifier;
- User’s Device functionality (including browser, operating system, hardware, mobile network information);
- User’s subscription level;
- the URL that referred User to Fertility Circle’s Website;
- the areas within Fertility Circle’s Website and/or Mobile App that User visits and User’s activities there, including remembering User, User’s preferences and pages User requested and/or viewed;
- User’s Device location;
- User’s Device characteristics; and
- certain other Device data, including the time of day, among other information.
Fertility Circle may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on User’s Device. The Tracking Technologies that may be used are the following (and subsequent technology and methods later developed which perform a similar function):
- Cookies. A cookie is a data file placed on a Device when it is used to visit the Website. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by User to User’s Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser User uses will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com. Please be aware that if User disables or removes cookies, Flash cookies, or HTML5 cookies on User’s Device, some parts of Fertility Circle’s Website, Mobile App and/or Services may not function properly, and that when User revisits Fertility Circle’s Website, Mobile App and Services User’s ability to limit cookies is subject to User’s browser settings and limitations.
- Web Beacons. Small graphic images or other web programming code called “web beacons” (also known as “1×1 GIFs” or “clear GIFs”) may be included in pages and messages of our Website, Mobile App and Services. Web beacons may be invisible to User, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, Mobile App and Services, to monitor how users navigate the Website, Mobile App and Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about User’s interactions with the Website, Mobile App and Services, such as the links User clicks on. The code is temporarily downloaded onto User’s Device from Fertility Circle’s web server and/or Mobile App or a third party service provider, is active only while User is connected to the Website and/or Mobile App, and is deactivated or deleted thereafter.
- ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Fertility Circle may use Tracking Technologies for a variety of purposes, including:
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Fertility Circle does not monitor or take any action with respect to these signals or other mechanisms.
Information Third Parties Provide About User
Interactions with Third-Party Websites
How Fertility Circle Uses the Personal Information
Fertility Circle may use User’s information that Fertility Circle collects about User:
- to contact User occasionally to inform User of new Services features, or news or articles Fertility Circle thinks will be of interest to User. Fertility Circle may send User regular updates on issues Fertility Circle thinks will be of interest to User;
- to contact User with regard to User’s use of the Services and, in Fertility Circle’s discretion, changes to the Services and/or the service policies;
- for internal business purposes;
- to provide User with information or services or process transactions that User has requested or agreed to receive including to send User electronic newsletters;
- to enable User to participate in a variety of the Service features;
- to process User’s account registration, including verifying User’s information is active and valid;
- to identify User as the author of any comments that User sends to Fertility Circle to be posted on the Website or Mobile App;
- to ensure that content on the Website and Mobile App is presented in the most effective manner for User and for User’s computer or mobile device;
- to provide User with information relating to any events held by Fertility Circle, where User has consented to be contacted for such purposes; and
- to provide User with access to User’s personal account.
User can always opt out of utilizing the Service, and accordingly opt out of Fertility Circle’s use of User’s Personal Information, by sending an email to email@example.com.
How and When Does Fertility Circle Disclose Information To Third Parties?
Fertility Circle may share User’s Personal Information associated with User’s name that is collected or generated at the Website, Mobile App or through the Services.
Personal Information may occasionally be transferred to third parties who act for Fertility Circle for further processing in accordance with the purposes for which the data was originally collected or for purposes to which User has subsequently consented. For example, sometimes a third party may have access to User’s Personal Information in order to support Fertility Circle’s information technology or to handle mailings on Fertility Circle’s behalf. If Fertility Circle transfers User’s Personal Information to an outside agent or organization for such purpose, Fertility Circle will take appropriate measures in an effort to protect User’s privacy and the Personal Information Fertility Circle transfer.
Fertility Circle may share your Personal Information with various business partners for the purposes of supplying services that you have requested or for purposes for which you have consented. We may also share your Personal Information as otherwise described to you at the time of collection.
Fertility Circle may, in Fertility Circle’s sole discretion, share or transfer Personal Information where permitted or required by law, to comply with legal process, to interact with anti-fraud databases, to protect User’s vital interests, to protect the security or integrity of Fertility Circle’s databases or the Website and the Mobile App, to enforce the Terms & Conditions or protect the business or reputation of Fertility Circle and/or its Premium Customers, to take precautions against legal liability, to protect and defend the rights or property of Fertility Circle and/or its Premium Customers, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to User’s use of the Website, Mobile App and Services.
Fertility Circle reserves the right to disclose and transfer all Personal Information: (i) to an operator of the Website or Mobile App or applicable database provided such entity agrees to be bound by the terms and conditions hereof to the extent applicable; or (ii) to a successor in interest of Fertility Circle in connection with a merger, consolidation, restructuring, change of control, the sale of substantially all of Fertility Circle’s interests and/or assets or other organizational change, including, during the course of any due diligence process, provided such successor entity agrees to be bound by the terms and conditions hereof.
What About Information User Disclose Publicly Or To Others?
User-Generated Content and Public Information. “User Content” is any content, materials or information (including without limitation, any text, information, graphics, messages, photos, images, and works of authorship kind), data, questions, comments, suggestions or other content, including personally identifiable information that you upload, send, email, display, perform, distribute, post or otherwise transmit to us, at our request or on your own, on, or through the Services (such as chat walls, diary logging), whether in connection with your use of the Services or through the use of any Third Party Websites or Third Party Services or otherwise, and whether publicly posted or privately transmitted.
Fertility Circle or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to User. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information User shares, including Personal Information, in connection with User’s User Content. Be aware that public postings (including group messaging with other Users) are not confidential. Please note that the Fertility Circle does not control who will have access to the information that User chooses to make public, and cannot ensure that parties who have access to such publicly available information will respect User’s privacy or keep it secure. Fertility Circle is not responsible for the privacy or security of any information that User makes publicly available on the Service, the Mobile App or Website or what others do with information User shares with them on the Mobile App and Website. Fertility Circle is not responsible for the accuracy, use or misuse of any User Content that User discloses or receives from third parties through the Service.
Name and Likeness. Fertility Circle may also publish User’s name, voice, likeness and other Personal Information that is part of User’s User Content, and Fertility Circle may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities, provided that Fertility Circle will not exercise such rights as to any User Content which identifies User in a public manner (other than in providing the Services to the Premium Customer and the Premium Customer’s other participants) unless User provides a separate consent to Fertility Circle in writing (email is sufficient) authorizing such use. For full terms and conditions regarding User Content User submits to the Service, please review Fertility Circle’s Terms & Conditions.
Profiles. A User’s profile page may be, by default, set up to display information such as the User’s display name, images, location (city/state/country), groups that the User has joined and optional information added by User. Profile information is used by Fertility Circle primarily to be presented back to and edited by User when User accesses the Service and to be presented to others permitted to view that information on the Service. Fertility Circle may offer users the ability to manage their public profile and use profile preference settings, the functionality and features of which are subject to change from time to time, so visit it frequently to confirm the settings reflect User’s then current preferences and Fertility Circle recommends that User does not post information or content as part of User’s profile that User is not prepared to make public. Changing setting options may not result in immediate changes to the settings, which are subject to Fertility Circle’s operations and maintenance schedules. User should carefully consider the use of such settings to improve information display options and to ensure the settings are properly set and functioning in the manner desired. Notwithstanding the availability of profile preference settings, User should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free. Further, other users that have access may repost or otherwise make public User’s information or content. Accordingly, discretion and good judgment should be exercised when posting information or content as part of User’s profile.
Use of Anonymous Information. We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about use of the Service.
Opting Out. You may choose not to receive future promotional, advertising, or other Service-related notifications from us by changing the notification settings on your device. If you choose not to receive notifications, you may still use the Service but you may not receive, or may be unable to use, certain services that involve our interaction with you.
Choice. At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Service in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still use the Service, but you may be unable to access certain programs and services that involve our interaction with you.
Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any other of your Personal Information that we may be storing, you may submit a request to us by sending an email to firstname.lastname@example.org. Your email should include adequate details of your request.
Links to Other Websites. The Service may contain links to third party websites that are not owned or controlled by us. We are not responsible for the privacy practices or the content of such other third party websites, and you visit them at your own risk.
Security. The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact us at email@example.com.
Please be aware that certain Personal Information and other information provided by you in connection with your use of the App may be stored on your device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.
Merger, Sale or Bankruptcy. If we are acquired by or merged with a third party entity, or if we are subject to a bankruptcy or any comparable event, we reserve the right to transfer or assign Personal Information in connection therewith.
Notice to California Residents
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
California Online Privacy Protection Act Notice
On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit us.
(1) We do not track users, who do not interact with its sharing functionality across the web, and therefore do not use “do not track” signals.
(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.
California Civil Code Section 1798.83 also permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
Personal Information Access and Corrections
Upon receipt of User’s written request and upon Fertility Circle’s receipt of enough information to permit Fertility Circle to identify User’s Personal Information, Fertility Circle will disclose to User the Personal Information Fertility Circle holds about User. Fertility Circle will also correct, amend or delete any Personal Information that is inaccurate and notify any third party recipients of the necessary changes. User may update any information User has given to Fertility Circle by sending an email to email@example.com. Requests to delete Personal Information are subject to any applicable legal and ethical reporting or document retention obligations imposed on Fertility Circle.
Notice to Residents of the European Economic Area
If you elect not to provide Personal Information
You may choose not to provide Fertility Circle with your Personal Information. However, if you choose not to provide your Personal Information, you may not be able to use our Services, as the processing of this information is necessary for the performance of our Services
How to exercise your rights
Fertility Circle takes steps to keep your Personal Information accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Personal Information that we have collected about you. To exercise your rights to your Personal Information, please contact us at firstname.lastname@example.org or at the address listed below. Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.
Right to lodge a complaint before the Data Protection Authority
We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes applicable data protection laws.
Changes to this Notice to Residents of the European Economic Area
In order to enhance our Services it might be necessary to change this Notice to Residents of the European Economic Area from time to time. We therefore reserve the right to modify this Notice to Residents of the European Economic Area in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Notice to Residents of the European Economic Area.
How to contact us or our privacy office as a Resident of the European Economic Area
In case of questions about the processing of your Personal Information please contact us at email@example.com.
If we are required under applicable law to appoint a data protection officer (DPO), you can contact the DPO that is responsible for your country/region at firstname.lastname@example.org.
Our Accountability/Dispute Resolution
Fertility Circle Service: International Users
In the event Fertility Circle goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, User’s Personal Information might be among the assets transferred. User will be notified via this Website of any such change in ownership or control of User’s Personal Information.
The Fertility Circle Group Ltd
71-75 Shelton Street
London, London WC2H 9JQ
Last Updated: 18 June 2021