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Privacy Policy

TFP Fertility Group (in the following also referred to as  “TFP”, “our”, “us” or “we”)


The Fertility Partnership Ltd

Institute of Reproductive Science, Oxford Business Part North, Oxford, OX4 2HW

Registreret virksomhedsnummer: 08765580


TFP is responsible for the processing of your personal data. We are the data controller and take the security of your personal information very seriously and strictly adhere to the rules of the data protection laws.


Personal data is only collected and processed if it is necessary. Under no circumstances do we transfer gathered data to a third party without a legal basis. This policy describes what information we collect, for what purposes and how we manage and process this data.


We reserve the right to adapt our data protection policy from time to time so that it reflects our activities to meet the current legal requirements. Therefore, please note that an updated data protection declaration may apply if you visit this website again.


TFP's Danish clinics are: TFP Stork Fertility A/S (CVR no. 33034911) and TFP Ciconia Fertility Aps (CVR no. 18021935). If you have any questions about our privacy policy or want to send a request, feel free to contact our Data Protection Officer or Regional General Manager at:


St. Kongensgade 40G, 1.sal

1264 København K

Telephone: +45 70 60 60 90



1. We process your data under the following legal basis

Consent (article 6 paragraph 1 lit. a GDPR) - where you have provided explicit consent for us to use (process) your personal data to supply information about TFP, its services, activities, news and for marketing purposes. We will always ask for your consent before processing your personal data, and you can change or withdraw your consent at any time by contacting us using the details provided in this policy. If you would like to withdraw your consent to which you previously opted in, you can also do so by contacting us either by post or email.

 

Provision of a Contract (article 6 paragraph 1 lit. b & article 9 (2)& (h) GDPR) which includes processing some personal information, including special categories of personal data, to perform a contract with you to provide our treatment services, including issuing prescriptions, communicating with other healthcare personnel, hospitals or laboratories or supply you with requested information; for managing job applications, members of staff and as contractors and sub-contractors.


Under a Legal Obligation (article 6 paragraph 1 lit. c GDPR) - other laws and regulations require us to collect, use, or share information - which means we have a legal obligation to do so and do not have a choice. In this instance, examples include:


  • To fulfil our legal obligations under the relevant fertility laws/legislation, EU data protection regulations and patient/ safety authorities when providing fertility treatment to patients e.g. the Danish Data Protection Act, the Danish Authorization Act, the Danish Health Care Act, the Agreement on Specialized Medical Assistance and the Danish Executive Order on Human tissue and cells.

  • Comply with existing legislation including EU data protection regulation,

  • to identify you when you contact us; and

  • to verify the accuracy of data that we hold about you.


In your Vital Interests (article 6 paragraph 1 lit. d GDPR) - We may use your personal information without your consent if we consider it in your vital interests to do so. In other words, using your information in this way will prevent or reduce any potential harm to you.


Our Legitimate Interests (article 6 paragraph 1 lit. f GDPR) - TFP will have a legitimate interest for using your personal information when you make contact with us or request information from us, and this will be used until you become a patient of ours, when we have a legal obligation to process your information to provide patient services.


As a rule, we do not process personal data accordingly for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (article 6 paragraph 1 lit. e GDPR).

 

TFP follows the data protection rules at all times and has implemented technical and organizational measures in its business processes to protect your data and has committed its employees to confidentiality. We don’t process or transfer data to a third party without a legal basis.


Your personal data will be deleted without delay after the purpose and legal basis for which it was processed has expired. Mandatory and statutory provisions, in particular healthcare, tax and commercial law retention periods, remain unaffected.


If we use service providers, we ensure an adequate level of data protection by means of data processing agreements in accordance with articles 26 and 28 GDPR as well as data protection certifications and EU standard contract clauses.


Please find additional information about data processing below. If applicable, please also review the data protection declarations of our service providers.


Sensitive personal data


Sensitive data includes: health data (e.g. data from your medical records, test results, samples, X-rays, scan results, etc.), sexual orientation, racial or ethnic origin and religious orientation. We use your data for the following purposes:

  • To examine, diagnose and treat you

  • To prepare medical reports

  • To prepare certificates for authorities, insurance companies, etc.

  • Communication with or referral to other health professionals, doctors, hospitals or laboratories.

  • Ordering medicines, including issuing prescriptions

  • Reports to statutory clinical databases

  • Reporting of laboratory tests to hospital laboratories

  • Invoicing

  • Comply with existing legislation, including the EU Data Protection Regulation, the Danish Data Protection Act and other relevant health legislation, e.g. the Danish Authorization Act, the Health Act, the Agreement on Specialized Medical Care and the Order on Human Tissues and Cells.

  • Processing of requests for inspections, complaints and/or statistical/research When we collect personal data directly from you, you give your consent to the processing of your personal data. You are not obliged to provide this personal data; however, we will not be able to investigate, diagnose or treat you without this information.



2. The use of data processors

TFP uses several trusted third parties to deliver our services. Your personal data may be processed and stored by our data processors, who store it on our behalf and based on our instructions in according to data protection agreements. Our data processors are amongst others:


  • DMDC (Formatex)

  • FocalScope

  • MD Consent (Fertility Consent)

  • Edudip (webinars)

  • Survey Monkey (client satisfaction surveys)


However, as some of our offices and trusted third parties are located outside EU, there may be times when your information may be transferred, disclosed or processed in another country (for example, United Kingdom). If you are located in the European Union, TFP uses mechanisms such as the EU Standard Contractual Clauses to transfer your information to other countries within the EU.



3. Your rights regarding your personal data


TFP only processes your personal data in accordance with data protection laws. You have the right of access, correction, deletion, and limitation of the processing of your personal data.


In addition, you have the right of data transferability, the right not to be subjected to a decision based solely on automated processing and a right of withdrawal. However, the legality of the processing is not revoked retroactively. Furthermore, you have a right of appeal to TFP or the responsible data protection supervisory authority.


If you would like to address data subject rights or have questions regarding the processing of personal data by us, please contact our Data Protection Officer by e-mail or mail.



4. Storage period


We will keep your personal data for as long as we need to fulfil the above purposes. However, according to the Danish Ordinance on Tissues and Cells, we are obliged to keep them for at least 30 years after the last entry in the medical record. There may be cases where we are obliged to keep your personal data for a longer period, for example in connection with a complaint or a compensation case. In this case, the data will be kept until the case is closed.



5. Contact information

If you contact us (e.g. via e-mail, telephone etc.), you consent to the processing of your submitted data (including e.g. name and e-mail address) in accordance with article 6 paragraph 1 lit. a GDPR for the purpose of answering your request and contacting TFP.


It might be necessary to forward your contact information internally to the appropriate department for adequate answers. You can revoke your consent free of charge at any time. The processing of personal data takes place on the basis of a legitimate interest within the meaning of article 6 paragraph 1 lit. f GDPR and, where appropriate, article 6 paragraph 1 lit. b GDPR for (pre)-contractual measures.


6. External Links


Please note that this policy only applies to the company’s main web pages (i.e. those in

www.tfp-fertility.com), where the data processing in our responsibility.

We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide) and provide them solely for your information and convenience.

Please check their policies before you submit any personal information; your disclosure of personal information to third party websites is at your own risk. Should we become aware of legal violations involving these external links, they will be immediately deleted.



7. Cookies

Cookies are small files created by websites you visit that make your online experience easier by saving browsing information. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. You can also disable, withdraw consent at any time, reject or clear cookies to erase all of the login or user data that was stored by changing your website browser settings. How you can do this will depend on the browser you use – check your settings for guidance. Please note that if you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.


For more information about the cookies we use, please see our Cookie Policy


Our website also uses the following third party links:


LinkedIn, Facebook Pixel, Google Maps, Google Tag Manager and Google Ads for conversion tracking and optimising, target group re-targeting, dynamic ads to present visitors who have visited this website with advertising, and interactive maps when using the site.


No user identifiable data is collected.


More information on the collection and use of the data by these sites as well as your rights can be found in their relevant data protection statements:





8. Online Events

For our online events we use the service provider edudip.com.


Depending on the date selected, your data for registering for the online event will be used to organize the event as well as for statistical evaluation.


We may contact you by telephone if you have given your consent to that or via email to obtain feedback following the event. If you do not wish to be contacted, please let us know. Your data will not be passed on to third parties.

 

Registration for an event is not binding and does not automatically result in a legal transaction, and you can cancel your registration for a planned event via the link provided in the confirmation email. Your data will be deleted from the system after approximately 30 days.


Edudip’s privacy policy can be found at:

 


9. Assessing the Quality of our Services


Periodically we will send you surveys to measure your experience of our services. The answers you give will be anonymous and used to improve the quality of our services. We use an external third party to conduct our client satisfaction surveys.

 

Valid from: 01/04/2022

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