Privacy Policy

PURPOSE

At TFP, we understand that embarking on the fertility journey can be daunting and emotionally challenging. As an integral part of our vision, we are dedicated to delivering an unparalleled patient experience by upholding the highest service standards. The primary purpose of this privacy policy is to ensure that all patients, suppliers, and internal employees of TFP receive exceptional support and care from our team, regardless of whether contact is made in person, over the phone, through email, or via online enquiries.

To achieve this goal, we adhere to the following principles when collecting personal data from data subjects:

• Providing Transparency: At the point of data collection, we furnish data subjects with essential information, including the identity and contact details of the controller, and where relevant, the controller's representative. Additionally, we share the contact details of our Data Protection Officer, ensuring clear lines of communication for data-related concerns.

• Stating Purpose and Legal Basis: We outline the specific purposes for which personal data will be processed and the legal basis for such processing. This enables data subjects to have a clear understanding of how and why their information will be used.

• Legitimate Interests: In cases where the processing is based on point (f) of Article 6(1), we disclose the legitimate interests pursued by TFP or by any third party involved. This ensures that data subjects are aware of the justifications behind the data processing activities.

• Recipients of Personal Data: We inform data subjects about the recipients or categories of recipients with whom their personal data may be shared, if applicable. This fosters transparency in data sharing practices.

• International Data Transfers: When applicable, we notify data subjects of any intention to transfer personal data to a third country or international organization. We also inform them of the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

By adhering to these principles and providing clear and concise information to data subjects, we aim to create an environment of trust and confidence in how we handle and protect personal data. At TFP, we are committed to ensuring the privacy and security of your personal information throughout your fertility journey and beyond.

TFP PRIVACY POLICY

At TFP, we value your trust and confidence. 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. We are committed to being transparent and ensuring the protection of your privacy.

General Information

This Privacy Policy describes how TFP Fertility Group Ltd and its affiliates and partners ("TFP," "we," or "us") collect and process your personal information when you visit our website, use our digital applications, and interact with us via our clinics, live chats, email communications, and social media channels (together, the "Services"). This policy applies to all company web pages under www.tfp-fertility.com.

WHAT DATA DO WE COLLECT?

You directly provide most of the information we collect. We collect and process data you provide via three methods:

Information that you provide us:

• Contact Information: Your name, email address, mailing address, and phone number when you register for TFP Services, subscribe to TFP marketing, communicate with us, or make an enquiry.

• Patient Registration Information: Information provided in connection with your TFP "Patient Profile," including contact information, username, medical history, weight, height, age, gender, and other relevant details you consent to provide.

• Communications Information: Details of your interactions with our clinical or support teams, including calls, emails, live chats, video calls, and social media interactions. We may record calls for training and monitoring purposes with your prior consent.

• Survey and Review Information: Information you provide in surveys or testimonials about TFP goods and/or Services.

• Other User Information: Any other data you provide related to your use of TFP Treatment or Services, such as event bookings, appointment scheduling, and personal experience feedback.

Information we collect automatically:

• Information generated through your use of the Services, events attended, appointments booked, classes attended, and phone enquiries made to TFP.

• Patient Feedback from Patient Experience surveys received.

• When someone visits TFP Fertility NL Homepage | TFP (tfp-fertility.com) we use Google Analytics: Standard internet tracking information collected anonymously to understand website usage patterns. We do not attempt to identify individual visitors through this data.

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:

• 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

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. How to Prevent Google Analytics from Tracking You (privacyaffairs.com).

MCK (Medisch Centrum Kinderwens) applies a camera policy for all security cameras used at the Leiderdorp location to protect the right to exist, the property and the staff of MCK and the safety of clients.

Information we collect from Third Parties

• Third-Party Applications: Information collected through third-party applications like App Stores or Social Networking Sites, where you have made certain data public via your privacy settings.

• Third-Party Sources: Information received from other sources to supplement the data you provide, enhancing our ability to provide information about our business, products, and Services.

HOW WE USE YOUR PERSONAL DATA

User-provided information:

• Personal information you provide to TFP will only be used for the stated purposes, such as providing information about our treatments and seeking feedback from you.

• Personal information will not be sold to third parties or provided to direct marketing companies without your explicit permission.

• While contacting TFP for treatment we ask you for your active and free consent according to Art. 6 (1) (a) Regulation (EU) 2016/679 of the European Parliament and of the Council (p. 36) 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.

Automatic demographic and statistical information:

• Information collected through Google Analytics is used to evaluate the effectiveness of TFP's website and improve content relevance and marketing campaigns.

• Any disclosure of this information will always be anonymized and will not identify individual users.

HOW WE STORE YOUR DATA

We are dedicated to safeguarding your data:

• Regular review of information collection, storage, and processing practices to protect against unauthorized access.

• Restricted access to personal information to authorized TFP/Clinic employees, contractors, and agents, subject to strict confidentiality obligations.

• Commercially reasonable administrative, technical, and physical safeguards to protect against unauthorized access, disclosure, or access of personal information.

• Personal information is stored on secure servers hosted by third-party contractor, Previder, in the Netherlands.

• For surveys, we use Feedbackradar and Bosgra Onderzoek, and all data transfers between TFP companies are governed by Data Protection Agreements (DPA). Patient Data will be stored at your registered clinic.

DATA RETENTION PERIOD

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy and comply with legal obligations. You have the right to request access, rectification, erasure, or to withdraw consent at any time.

MARKETING

We may send you information about our products and services, and those of our affiliates or partners, with your consent. You can unsubscribe from marketing communications at any time.

COOKIE TECHNOLOGY

Our website uses cookies to improve your browsing experience. You have the option to disable non-essential cookies via your browser settings. For more information about managing cookies in popular browsers, see your browser's Help page. Disabling certain cookies may affect the functionality and user experience of the website.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may disclose your personal information to the following categories of recipients:

• Group Companies, Third-Party Service Providers, and Business Partners: Information shared to provide IT, analytics, payment processing, technical support, and marketing services. Data Protection Agreements are in place.

• Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts, or other Third Parties: When required to comply with the law, establish legal rights, protect vital interests, or detect/prevent security or fraud issues.

PRIVACY POLICY FOR OTHER WEBSITES

Our privacy policy applies to our website. If you follow a link to another website, please review their privacy policy.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, processed, and stored in countries other than your resident country, including the European Union and UK. Appropriate safeguards are in place to protect your data during such transfers.

YOUR RIGHTS

You have the right to access, rectify, erase, restrict processing, object to processing, and data portability. You may withdraw consent for data processing at any time. For data-related inquiries, contact our Data Protection Officer at privacy_mckinderwens@tfp-fertility.com.

LEGAL BASIS FOR PROCESSING

TFP Fertility Group Ltd collect information from individuals for various purposes related to providing fertility-related services, ensuring effective care, complying with legal requirements, and safeguarding the vital interests of individuals.  The legal basis for processing data is shown below:

• Contractual Performance: TFP collect and processes personal information based on the necessity of fulfilling the contractual obligations between TFP and the individuals supply data. This includes data required for scheduling appointments, providing fertility treatments, managing patient records, and processing payments for the services rendered.

• Legitimate Interests: TFP process personal data based on legitimate interests pursued by TFP or third parties. For instance, these legitimate interests might include improving the quality of fertility treatments, conducting research to enhance fertility outcomes, or optimizing internal processes to ensure better patient care. TFP will also ensure that these legitimate interests are balanced with the rights and freedoms of the individuals whose data is being processed.

• Consent: TFP seek explicit consent from patients or individuals for specific data processing activities. This could include obtaining consent for conducting fertility-related research studies, sharing medical information with other healthcare providers, or using personal data for marketing purposes. Consent should be freely given, informed, and easily revocable by the individual at any time.

• Legal Obligations: TFP is subject to various legal requirements and regulatory obligations. Data processing may be necessary to comply with these legal obligations, which could include maintaining accurate medical records, reporting certain medical conditions to health authorities, and adhering to data protection and healthcare laws.

• Protecting Vital Interests: In certain critical situations where an individual's life or health is at risk, TFP may process personal data based on the vital interests of the individual. For example, during emergency medical situations, TFP may access relevant medical information to provide timely and appropriate medical care.

It's essential for TFP to be transparent and inform individuals about the specific purposes for which their data is being collected and processed, as well as the legal basis for each processing activity. Patients should also be made aware of their rights regarding their personal data, including the right to access, rectify, erase, and object to the processing of their data. By adhering to data protection regulations and ensuring clear communication with patients, fertility companies can build trust and maintain the confidentiality and security of personal information.

CHANGES TO OUR PRIVACY POLICY

We regularly review our compliance with this privacy policy. Any changes will be posted on our website and, where appropriate, notified to you by email.

Last updated on 21 December 2023.

HOW TO CONTACT US

The Data Protection Officer will answer any questions you have about this privacy policy or information we hold. Please contact us in any of the following ways:

For privacy inquiries or to exercise your rights, contact our Data Protection Officer at dpo@tfp-fertility.com or call +44 808 164 5341. You can also reach us by post at TFP Ltd, Institute of Reproductive Sciences, Oxford Business Park North, Alec Issigonis Way, Oxford, Oxfordshire, OX4 2HW, United Kingdom.

 [BB1]Not in NL

 [BB2]I’ve put in the NL link