We will collect and use your personal data in a variety of ways. In particular, we collect and use your data when you;
(i) provide us with a review about a clinic;
(ii) browse and use our website, including the postcode search facility;
(iii) subscribe to receive our newsletter;
(iv) create an account with us; and
(v) purchase our specialist guides.
Under data protection law, the ‘controller’ is the organisation responsible for ensuring that your personal data is used lawfully and appropriately. FertilityMapper is the controller and responsible for your personal data.
Full name of legal entity: Fertility Mapper Limited
Email address: email@example.com
Postal address: 9 Bonhill Street, London, United Kingdom, EC2A 4DJ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
As set out above, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the unique identifiers relating to you have been removed (anonymous data). For example, we do not include your name, address, or other details from which you can be identified in the published versions of your reviews to ensure that they are fully anonymised.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks such as Google based outside the UK; and
(c) search information providers such as Google based outside the UK.
In order to use your personal data, we must do so ‘lawfully’. This means we must satisfy what is known as a ‘lawful basis’ under the data protection legislation. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity (b) Contact||(a) Necessary for our legitimate interests (to give effect to your registration)|
|To enable you to find a clinic near you||(a) Identity (b) Contact||(a) Necessary for our legitimate interests (to keep our records updated and to study the location of our customer’s clinics)|
|To enable you to leave a review on our website about your experience at a clinic||(a) Identity (b) Contact||(a) Necessary for our legitimate interests (to be able to match future patients to the best clinic in accordance with their needs)|
|To enable us to verify your review||(a) Identity (b) Contact||(a) Necessary for our legitimate interests (to be able to verify that the user has received services from the relevant clinic so that we can match future patients to the best clinic in accordance with their needs)|
|To process your purchases including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to report a review||(a) Identity (b) Contact||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to ensure we meet the legal requirements relating to our website and to maximise user satisfaction).|
|To enable us to send you emails subscribe to our newsletters||(a) Identity (b) Contact (c) Marketing and Communications||(a) Consent|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Consent|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||(a) Consent|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||(a) Consent|
|To anonymise data for the purpose of sharing trends with clinics from the reviews of their goods or services||(a) Profile||Necessary for our legitimate interests (to develop our business)|
Special Categories of Personal Data
We process special categories of personal data in accordance with Article 9 of the UK General Data Protection Regulation (‘GDPR’), when you leave a review on our website, including when you provide us with information to enable us to verify your review. ‘Special categories of personal data’ are a more sensitive form of personal data according to data protection legislation, and attract additional protection. In particular, we must satisfy an additional lawful basis in order to use any personal data which. Special category data includes personal data revealing:
The only special categories of personal data we will process about you is in the specifics of your treatment which you provide when leaving a review and if you complete our review verification document and/or provide additional information for the purpose of enabling us to verify your review. For the avoidance of doubt, however, your reviews will only be published in anonymised format, such that your special category data is only identifiable to us and not other users of our services and the contents of your review verification document and any other information you provide to us for the purpose of verifying your review will not be published. In order to hold that data about you we rely your explicit consent to do so.
You will receive marketing communications from us if you have consented to us doing so, joined our mailing list, signed up for an account, signed up to our newsletter or purchased goods or services from us and you have not opted out of receiving that marketing. You may opt out of communications from us by unsubscribing from the footer of any email you receive from us or by contacting us with your request at firstname.lastname@example.org at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Where you opt out of receiving marketing messages, either from us or third parties, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies and similar technologies
A cookie is a small piece of information that is placed on your computer when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers.
We use the following types of cookie, as will your browser:
We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.
Managing your cookies preferences
Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site.
We also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is our cookie management tool:
We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below, to view their websites and privacy policies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will not usually share your personal data with third parties. We will, however, share your personal data with the following:
We do not transfer your personal data outside the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our website users (including Contact, Identity, Financial and Transaction Data) for six years after you cease being a user. Where you have created an account on our website and have decided to close your account, your personal data will be held for up to an additional six months, unless you consent to us sending you marketing material.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for ongoing use, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Explicit Consent means processing your personal data where consent has been expressly confirmed in words.