Why you should read this policy
‍
We take the privacy of your personal data very seriously. We ask that you read this privacy policy (‘Policy’) carefully as it contains important information on who we are, how and why we collect, store, use and share your personal information and your rights in relation to your personal information.

Who we are

https://www.fertifa.com & https://www.fertifabenefits.com/Splash.jsp (‘Website’) is brought to you by Fertifa Limited, a company incorporated and registered in England and Wales under company number 12151532 whose registered office address is at 7 Savoy Court, London, United Kingdom, WC2R 0EX (‘we’ or ‘us’).

We collect, use and are responsible as a controller for certain personal information about you.

Our collection and use of your personal information

Information that you provide

We will obtain personal information you provide when you send us feedback, submit data onto our website and service platform, via email or over the phone, complete forms, report a problem with the website or our platform, contact us for any reason and by any medium and when you sign up for our services.

We may also collect, store or process data that is labelled as special category personal data under the UK General Data Protection Regulation (“UK GDPR”). If such data is requested and/or required, you will be given additional information as to why the sensitive personal data is being requested and how it will be used, often this will be required to provide you with our services.

We may retain a record of any contact you make with us.

The personal information we collect about you depends on the particular activities carried out and the reason for the processing. Such information includes, but is not limited to:

• your name, address and contact details;
• occupation;
• emergency contact details including your next of kin;
• details of any feedback you give us by phone, email, post or via social media; and
• information about the services we provide to you.

In relation to the special category data we collect, such information includes, but is not limited to:

• information regarding your health, including your current and historical physical or mental health and diet;
• your nationality, race and/or ethnicity;
• details of your sex life;
• genetic information; and
• sexual orientation.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her data;
• receive on his/her behalf any data protection notices;
• give consent to any transfer of his/her data.

Information from third parties

We may collect personal information about you from a number of different sources including, but not limited to:

• Your GP;
• Other hospitals, both NHS and private;
• Mental health professionals / service providers;
• Commissioners of healthcare services;
• Clinicians (including their medical secretaries);
• Your current or former employer, health professional or other treatment or benefit provider;
• Your family;
• Experts, including medical experts, and other service providers about services you have received and/or are receiving from us; and
• Credit reference Agencies.

Information that will be collected automatically

Cookies: We may monitor your use of the Website through the use of cookies and similar tracking devices. For example, we may monitor how many times you use the Website, which pages you go to and traffic data.  This information helps to build a profile of users to the Website. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on the use of cookies on the Website, please see the sections on cookies below.

How your personal data will be used

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

Disclosure of your personal data

We may disclose your information to third parties including, but not limited to:

• third parties we us to help deliver our services to you, e.g. healthcare providers/organisations (including the NHS and private sector), clinics and other health professionals for example.
• Anyone that you ask us to communicate with or provide as an emergency contact, for example your employer, next of kin or care provider;
• Other third parties that you ask us to provide information to, for example any clinics you wish to utilise for treatment that are not affiliated with us;
• other third parties we use to help us run our business, e.g. website hosts, payment providers such as Stripe;
• credit reference agencies;
• our insurers and brokers;
• our bank.

We only allow our service providers and preferred clinics to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

If your employer is covering some or all of the cost of the services we provide to you, these may be subject to income tax in relation to you, as it is a benefit-in-kind.  To comply with tax reporting requirements in relation to you, your employer needs to know the value of the treatments that they have paid for. For us to provide you with our services, where your employer contributes to the cost, we must provide this value information to your employer. Whilst we must provide this information to provide you with our services in these instances, we will not provide any information in relation to the treatment being received by you.

When providing your personal information onto clinics for your proposed treatment, we will always ask for your consent to share this information before doing so.

Please be aware that the clinics and/or health professionals we provide your personal information to may be required to provide this information to their regulators and other third parties. You should ensure that you are familiar with their privacy notices.

Transfer of your information out of the EEA

To deliver our services to you, it is sometimes necessary for us to store and process your personal information outside the European Economic Area (EEA).

These transfers are subject to special rules under European and UK data protection law.

We will only transfer data to the extent that it is relevant and necessary, and to the extent that there are sufficient safeguards in place.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

Marketing

We may use your personal information to send you updates by email about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations for their own marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at Info@Fertifa.com
• using the ‘unsubscribe’ link in the emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Your Rights

Under the General Data Protection Regulations (GDPR), you have the following rights:

• You have the right to be informed about the collection and use of your personal data.
• You have the right of access to your personal records or other information that we hold about you. We reserve the right to charge a reasonable fee for our administrative costs involved with providing you with access if we receive a request which is manifestly unfounded or excessive to access personal records. We may also charge a reasonable fee, in relation to administrative costs, if further copies of your data is requested following your initial request.
• You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
• You may have the right to have the data we hold about you erased.
• You have the right to restrict processing.
• You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
• You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you in an electronic format such as a PDF file, CSV file or via other electronic means. We reserve the right to charge a reasonable fee for the administrative costs of complying with any requests that are manifestly unfounded or excessive.
• You have the right not to be subject to automated decision-making, including profiling.

To revise your consent, request access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at Info@Fertifa.com.

You may need to provide proof of identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed.

How long we will store your data

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Children

Due to the nature of our business, we may collect the personal information of any children born following any successful treatment. This privacy policy will also apply to any child’s personal information we collect and process. We may ask your permission to utilise this information for the purpose of publicising any success stories.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also confirm that your data will be stored on secure servers.

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.

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the Website. We use cookies and other online tracking devices on the Website for the purposes noted below.

The information we obtain from the use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you, but only where you voluntarily provide it.

In most cases we will need your consent in order to use cookies on this Website. The exception is where the cookie is essential for the operation of the Website or is in order for us to provide you with a service you have requested.

Description of cookies

The cookies that we utilise on our Website are placed to fulfil such functions as analysing how you use the Website to give you a better and more personalised experience, generate statistical data.

The cookies we utilise on our Website include:

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.

Changes to this Policy

This privacy policy was last reviewed on 15 March 2024 and last updated on 5 April 2023.

We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the Website.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you. Our Data Protection Officer is Giuliano Sison who will deal with any queries you may have.

If you wish to contact us, please send an email to Info@Fertifa.com with FAO DPO Giuliano Sison in your subject line or write to Fertifa Limited, 7 Savoy Court, London, WC2R 0EX FAO Giuliano (DPO).

Concerns and Questions

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.