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Privacy Policy
TFP Privacy Policy
At TFP, we are committed to maintaining the trust and confidence of our visitors to our web site and contacting our clinic teams across the globe. This privacy policy explains what types of personal information will be gathered when you visit TFP's website, how we keep it secure and how this information will be used.
General Information
This Privacy Policy describes how TFP Ltd and its affiliates ("TFP", "we", or "us") collect and process your personal information when you visit our website site, along with the uses of any TFP services including the digital applications, when you use or when you interact with us via our clinics, Patient care services inclusive of our live chats, digital app “Dia” e-mail communications, and social media channels. (Together, the "Services"). Please note that this policy applies to all company’s web pages (i.e., those in www.tfp-fertility.com).
We may also collect information about your computer, including where available, your IP address, operating system, and browser type for system administration and to report aggregate information to our webmasters. This is statistical data about our users’ browsing actions and patterns which does not identify any individual and allows us to ensure that content from our site is presented in the most effective manner for you and for your computer.
1. What data do we collect
You directly provide your company with most of the information we collect. We collect and process data you provide via three methods.
1.1. Information that you provide us
Contact Information: Your name, email address, mailing address, phone number that you provide to us, for example, when you register for any TFP Services, subscribe for TFP marketing, communicate with us, or register an enquiry.
Patient Registration Information: Any information that you provide to us in connection with your TFP "Patient Profile", such as contact information listed above, username, and any additional information you choose to provide to enhance your use of the Services, including your medical history, weight, height, age, gender, general location, or other third-party materials supplied to us with your consent.
Communications Information: Any details of your communications/interactions with us, including when you call, email, live chat, video call or text with our clinical or support teams or communicate with us via social media channels or community forums. We may record calls for training and monitoring purposes and to help resolve patient experience issues. We will tell you before recording and, where required by applicable laws, obtain your consent for the collection of these recordings.
Survey and Review Information: Any information you provide to us (or otherwise publish) in connection with a survey you complete or review / testimonial you provide about TFP goods and/or Services.
Other User Information: Any other information that you may provide to us in connection with your use of any TFP Treatment or Services, which include but are not limited to booking onto event, organizing an appointment, being provided additional information about your medical history, or submitting personal experience feedback.
1.2. Information we collect automatically
Information generated through use of the Services. Such as events attended or appointments booked, classes attended, and phone enquired made to TFP.
Patient Feedback from Patient Experience surveys received.
Google analytics- When someone visits www.tfp-fertility.com we use a third-party service, Google Analytics, to collect standard internet tracking information and details of visitor behaviour patterns. In case of a merely informative use of the website, for example if you do not request a call, book an appointment, or disclose to us data in other ways, we collect only those personal data which your browser transmits. If you visit our website, we collect the data below which are technically necessary for us to show you our website and ensure its stability and security (the legal basis for this is Art. 6 paragraph 1 clause 1-point (f) GDPR):
IP address.
Date and time of your inquiry.
Time zone difference to Greenwich Mean Time (GMT).
Content of the request (actual page).
Access status/HTTP status code.
Transmitted data volume.
Website from which the request is received.
Browser.
Operating system and its interface.
Language and version of the browser software.
We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Privacy Policy – Privacy & Terms – Google
You may want to opt out of your data being used by Google Analytics, Google Analytics opt-out browser to learn more about the opt-out and how to properly install the browser add-on here.
1.3. Information we collect from Third Parties
Third Party Applications: If you access our Services through a third-party application, such as the Apple App Store or Google Play App Store (together with any similar applications, "App Stores") or Social Networking Sites ("SNS") such as Instagram, Twitter or Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. This may include: your name, your SNS user ID, your App Store username, location, sex, birth date, email, profile picture and your contacts on the SNS. Please note the legal bases below in 10.0 Legal basis for processing.
Third Party Sources: We may receive information about you from other sources to supplement information provided by you. The supplemental information allows us to enhance our ability to provide you with information about our business, products, and Services and to provide you with any marketing communications that you have provided your consent to receive. Please see Your Rights below for how to unsubscribe.
2. How we use your personal data
2.1. User-provided information
Personal information provided to TFP by you will only be used for the purposes stated when the information is requested, which includes but is not limited to providing you with information about our treatments and seeking feedback from you about us.
Be assured that personal information will not be sold to third parties or provided to direct marketing companies or other such organizations without your express permission. Personal information collected and/or processed by TFP is held in accordance with the provisions of the General Data Protection Regulation 2018.
While contacting TFP for treatment we ask you for your active and free consent according to Art. 6 (1) (a) GDPR for taking part in our patient feedback surveys. Based on your content you will receive emails asking you about your experience during the different stages of your treatment. The process controller for sending the mails is your clinic, for the surveys we need: your first and last name, your email address and the questions and answers in the survey. Please note, the survey results are personal and could be – theoretically – associated to your patient file within the clinic. It is possible, that a staff member of the clinic contacts you afterwards the survey e.g. for discussing what you need for a complete treatment or how to improve negative aspects.
We may also download the data collected into the clinics to provide the service requested (such as to book a place on an open event), but we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
2.2 Automatic demographic and statistical information
Demographic and statistical information about user behavior collected via Google Analytics is used to evaluate the effectiveness of TFP's website and to help enhance our content to be more useful, such as seeing which pages most used, which pages people are spending the most amount of time on, etc. We also use it to look at the impact of our marketing campaigns, for example, to see if more referrals come from a specific website we have been partnering with.
Any disclosure of this information is always anonymized and will never identify individual users.
3. How we store your data
We work hard to protect TFP, our clinics and our users from unauthorized access to, or unauthorized alteration, disclosure, or destruction of information that we hold. In particular:
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We restrict access to personal information to TFP/Clinic employees, contractors and agents who need to know that information to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined, or their contract terminated if they fail to meet these obligations.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect against unauthorized use, disclosure, or access of personal information.
Information which you provide to us will be stored on our secure servers. Our group servers are hosted in London by a third-party contractor called DigitalOcean which complies with all EU privacy regulations including GDPR. You can view their privacy policy here: https://www.digitalocean.com/help/privacy/
For the surveys we use as a service provider AskNicely, registered in Portland, Oregon, USA and settlement in Amsterdam, Netherlands: Suite 250, Unit 118, 1016 AB, Amsterdam, Netherlands. You find the privacy policy by AskNicely here: https://www.asknicely.com/privacy . We concluded a Date Protection Agreement (DPA) with AskNicely – see https://www.asknicely.com/data-processing-addendum. We do not transfer the survey results to third parties. Within TFP Group we concluded a DPA as well for data transfer between TFP companies in case our headquarter should need access to the data.
Patient Data will primarily be stored at your registered clinic.
4. Marketing
TPF Ltd. Would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies. We may send marketing communications for purposes notified to you and, where required by applicable law, with your consent. You can unsubscribe from direct marketing at any time by following the instructions below or by contacting us using the details provided under the How to Contact Us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Unsubscribe options are provided in electronic marketing communications as required by applicable law.
5. Cookie Technology
Like most webpages, our web pages use “cookies”. A cookie is a small file of letters and numbers that we place on your computer or mobile device if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and allows us to improve our website.
According to German law, we process the (personal) data according to § 25 TTDSG (Telekommunikations-Telemedien-Gesetz).
5.1. How do I disable cookies?
If you want to disable cookies, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:
5.1.1. For Microsoft Internet Explorer:
Choose the menu item “Tools” then “Internet Options”.
Click on the “Privacy” tab.
Click on the “Advanced” button.
Choose the appropriate settings you would like.
5.1.2. For Google Chrome:
Choose Settings > Advanced.
Under “Privacy and security,” click “Content settings”.
Click “Cookies,” and choose the appropriate settings you would like.
5.1.3. For Safari:
Choose Preferences > Privacy.
Click on “Remove all website data”.
5.1.4. For Mozilla Firefox:
Choose the menu item “Tools” then “Options”.
Click on the icon “Privacy”.
Find the menu item “Cookie,” and select the relevant options.
5.1.5. For Opera 6.0 and further:
Choose the menu item "Files", then “Preferences”.
Click on "Privacy," and choose the relevant options.
5.2. What happens if I disable cookies?
This depends on which cookies you disable, but in general, the website may not operate properly if cookies are switched off. Further information can be found in our cookie policy.
6. Who we share your personal information with
6.1. We may disclose your personal information to the following categories of recipients:
Group Companies, Third Party Service Providers and Business Partners: We may share your personal information with other members of our group, with our third-party service providers (such as those who provide IT, analytics, payment processing, service providers and technical support), third party business partners who otherwise process personal information for purposes that are described in this Policy or who are otherwise notified to you. We do not sell your personal information. We conclude Data Protection Agreements (DPA) according to Art. 28 GDPR with every contraction party before processing.
We ask you for your active and free consent according to Art. 6 (1) (a) GDPR for taking part in our patient surveys. Based on your interactions with TFP you receive several mails with links to survey questions during the different stages of your treatment in our clinics. The process controller for sending the mails is your clinic. For the surveys we need: your first and last name, your email address and the questions and answers in the survey.
Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties: We may share your personal information, including CCTV images, with competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish or defend our legal rights; (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent or otherwise address security, fraud or technical issues. and private sector organizations, such as those offering fertility programs, but this will only be in the exceptional circumstances listed above.
7. Privacy Policy for other websites
The TFP Website contains links to other third-party websites. Our privacy policy applies only to our website, or when you consent to our policy on a third-party page who collect data on our behalf. If you follow a link to any other website, you should read their privacy policy.
8. International Data Transfers
Your personal information may be transferred to, processed, and stored in countries other than the country in which you are resident, including the European Union and UK. The recipients of such information may be in any country where TFP has a place of business and additional territories where our suppliers and partners may transfer data, details of which can be provided upon request.
We take appropriate safeguards to protect your personal information in accordance with this Privacy Policy specifically in relation to any international transfer. This includes implementing an intra-group data sharing agreement that includes safeguards and protections for any use of your personal information by our group entities and incorporates the European Commission's Standard Contractual Clauses, which require all group companies to protect relevant information in accordance with European Union and UK data protection laws.
We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
9. Your Rights
TFP would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
9.1. Your rights to access and manage personal information
The General Data Protection Regulation gives you the right to access information held about you. We aim to provide you with access to your personal information. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate unless we must keep that information for legitimate business or legal purposes.
To do so, please contact our Data Protection Officer using: dpo@tfp-fertility.com
9.2. The right to rectification
You have the right to request that TFP Ltd correct any information collected and process you believe is inaccurate. You also have the right to request TFP Ltd to complete information you believe is incomplete, by contacting us using the details provided under How to Contact Us.
9.3. The Right to erasure
You have the right to request that TFP Ltd erase your personal data, under certain conditions. You can request this by contacting us using the details provided under How to Contact Us.
9.4. The Right to restrict processing
You have the right to request that TFP Ltd restrict the processing of your personal data, under certain conditions. You can request this by contacting us using the details provided under How to Contact Us.
9.5. The Right to object or processing
If we have collected and process your personal information with your consent (including any sensitive or special category data), then you can withdraw your consent at any time by using settings on your device or by contacting us using the details provided under How to Contact Us.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Email, SMS and Telephone:
You can unsubscribe from email communications at any time. To stop receiving our emails, follow the unsubscribe instructions in the email messages you receive from us, or contact us using the details provided under the How to Contact Us. We will process your request as soon as practicable after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding our Services and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).
We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within the timescales required by law.
10. Legal Basis for processing
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned, applicable laws and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as to provide our Services), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Services, to communicate with you as necessary to provide our Services to you, and for our legitimate commercial interests such as responding to your queries, improving our Services, undertaking marketing, or detecting and preventing illegal activities. We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, you can contact us using the details provided under the How to Contact Us section below.
11. Changes to our Privacy Policy
We regularly review our compliance with our privacy policy. We also adhere to national data protection regulations. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
This privacy policy was last updated on 18 September 2022.
12. How to contact us
If you have any questions about our privacy policy or on the information we hold, feel free to contact us in any of the following ways:
By email
Please email the Group Data Protection Officer at dpo@tfp-fertility.com.
By phone
Call 0808 164 5341 and ask for the Group Data Protection Officer.
By post
The Data Protection Officer TFP
Institute of Reproductive Sciences,
Oxford Business Park North,
Alec Issigonis Way,
Oxford, Oxfordshire,
OX4 2HW United Kingdom
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