Assured Fertility Limited (“the Company”, “we”, “us” and “our””) is registered in England, company number 1831618. Its registered office is at 1 Worsley Court, High Street, Worsley, M28 3NJ. The Company is an Appointed Representative of Chrysalis Finance Limited, which is authorised by the Financial Conduct Authority under FRN 631193 to carry out the regulated activity of credit broking, and it is registered with the Information Commissioner’s Office under reference ZA225783.
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Information on this website is intended as general guidance only and should not be treated as medical advice, which should always be sought from a qualified medical practitioner.
Assured Fertility Limited is committed to protecting your privacy. This notice sets out the personal information that we may collect or obtain about you and how we treat that information.
For the purposes of applicable data protection legislation, we are a data controller in respect of the information that we collect or obtain about you. This is because the Company is the person who (either acting alone or jointly with others) determines why and how your personal information is processed.
The information we process about you
Your personal information will be collected or obtained by us whether we deal with you as an individual or on behalf of an individual. Broadly, personal information (or ‘personal data’) is any information that can identify you as an individual. We process many different types of personal information (for example, your name, address and date of birth). We may also process ‘special categories’ of personal information (for example, information relating to your health). Note that if you provide us with documents that contain, or otherwise volunteer to us, data that constitutes a special category of personal information, then you will be regarded as giving your explicit consent to us processing that data as described in this privacy notice.
If you have made an application on behalf of another individual or a joint application with another individual, and have provided us with information, then this privacy notice will also apply to the information that we collect or obtain about those individuals. You must provide a copy of this notice to those individuals as soon as possible and obtain their confirmation that they have read and understood it.
Why we process your personal information
We process your personal information for a variety of reasons, upon different legal bases, depending on the reason for which we have collected or obtained your personal information. The main types of processing that we carry out and the legal basis for doing so are as follows:
- We process your personal information in order to consider and process your application for an Assured Fertility Plan and related treatment. This is necessary in order to take steps at your request before we enter into an agreement with you and is also necessary for our legitimate interests (i.e. in deciding whether or not we can offer you the product you have applied for). This type of processing is required in order for you to enter into an agreement with us. If you do not provide it, then we cannot proceed with your application. If your application is accepted we will process your personal information in order to process your fertility plan and treatment. This type of processing is necessary for the performance of our contract with you and in order to fulfil our legal obligations.
- We will also process your personal information to manage our business operations, for example, our internal governance functions, which will include monitoring communications and activities in relation to your treatment (see further detail in relation to monitoring communications below), and for accounting and audit purposes. We have legitimate interests in doing so (i.e. it is necessary for our business and compliance purposes) and we may also have legal obligations to fulfil.
- If your application is declined we will store your personal information in accordance with our record retention procedures and to comply with our legal obligations.
- If we are dealing with a request you have made in order to exercise your legal and regulatory rights (including those referred to in the ‘Your rights regarding your personal data’) below, this will be done in order to fulfil our legal obligation to respond to you.
- We process your personal information for marketing purposes. This is necessary in order to fulfil our legitimate interests of providing you with information about products and services that you may be interested in.
Any consent that you give us will be as easy to withdraw as it was to give. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent. If you do this, and if there is no alternative legal basis upon which we may process your personal information for a particular purpose, then this may affect what we can do for you.
Who your personal information may be shared with
We may share your personal information with the following third parties:
- A consultant or clinic for the purpose of assessing your eligibility for an Assured Fertility Plan treatment or for the treatment itself.
- Legal and regulatory bodies, such as the Information Commissioner’s Office (ICO), our professional advisors and/or the courts when it is necessary for our legitimate interests and/or when we have a legal obligation to do so.
- Organisations that provide us with business support services. For example, account service and administration companies, back-up and server hosting, IT software and maintenance and platforms, document storage and management services, receivers, repossession agents, recoveries agents and property valuers. This processing is undertaken as it is necessary for the performance of our agreement with you and is necessary for our legitimate interests (i.e. for our commercial operations or with respect to your treatment).
- Third parties (intermediaries) who have introduced you to us (e.g. a clinic or consultant) in order for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate and to help us to resolve any complaint made by you and/or any dispute between you and us. This type of processing is necessary for our legitimate business interests (e.g. to help us to ensure that the intermediary is fulfilling the terms of their contract with us) and in order for us to fulfil our legal obligations (e.g. our complaint-handling obligations) or with respect to your treatment.
- Market research organisations who we engage to assist us in developing and improving our products and services. This type of processing is necessary for our legitimate interests (e.g. for our commercial operations).
- Any entity (and their professional advisors) that provides funding to us, any entity that provides us with debt or equity finance and any potential purchasers of any part of our business. This type of processing is necessary for our legitimate interests (e.g. to enable us to fund our business).
As mentioned above, if you voluntarily provide us with special categories of your personal information, this will be regarded as constituting your explicit consent to us processing such information. This includes us sharing that information with third parties as necessary. For example, if you provide information relating to your health, a complaint you have made or any financial difficulties you may be experiencing, then you will be consenting to us sharing that information with our medical or professional advisors, any third party who introduced you to us (e.g. an intermediary or broker), administration companies or the FOS (as is relevant).
How we collect and obtain your personal information
We may collect your personal information directly from you a number of ways, including:
- when you provide it by telephone, on-line, via social media or by any other method of communication, for example, on “contact us” forms, or when you provide it through the course of our relationship, for example, if you inform us of a change in your circumstances; and
- technical information, including the Internet Protocol (IP) address used to connect to the internet, may be collected from you when you visit our website.
We may obtain your personal information from third parties in the following ways:
- from a clinic for consultant who is or has provided you with medical advice or treatment if another person provides your information to us when they apply to obtain a product from us.
If you are applying to us through a third party (such as a clinic or consultant), then they should have provided you with their own privacy notice in order to tell you (whether online or in person) how they may process your personal information. They should have also told you that your personal information is being shared with us for the purposes and uses set out in this privacy notice. If the third party did not tell you this, then you should let us know immediately by contacting our Data Protection Officer using the contact information set-out in the ‘Introduction’ section of this privacy notice.
International transfers of your personal information
Your personal information may be transferred outside the UK and the European Economic Area (EEA). Should we transfer your personal information to any other territories or countries outside the EEA we will take such steps as are necessary to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under data protection laws in the UK. If we do so you may contact us to obtain a copy of the applicable safeguards.
Assured Fertility stores data online using Dropbox, Microsoft and Pipedrive software applications. All of these providers comply with GDPR regulations, including certification under the EU-US Privacy Shield Framework.
Your rights regarding your personal data
You have the right to request a copy of the personal data we hold about you. If you would like a copy, please contact us using the details below. We may make a small charge for this service. You may ask us to correct or remove personal data you think is inaccurate.
You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; (iii) the right to opt-out of receiving direct marketing messages; (iv) the right to request the correction of inaccurate personal information we hold about you; (v) the right to request the blocking or deletion of your personal information where the processing does not comply with applicable data protection laws and; (vi) the right to request that we port elements of your data either to you or another service provider.
Third party websites
Our website may contain links to third-party sites not operated by the Company, such as Facebook or Twitter. These websites are not under our control and, as such, we are not responsible for the content of them or for their privacy practices. If you choose to use any linked third-party website, any personal data collected by that site will be controlled by the privacy notice of that third party.
How long your personal information will be stored for
We only keep your personal information for as long as it is necessary to fulfil the purposes for which it is processed (as described above).
In accordance with our retention policy, we will retain your personal information for a minimum of six years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your contract with us ceases or when your application for an Assured Fertility Plan has been declined. We will retain your personal information and continue to communicate with you whilst you are a possible customer for our services, but you can notify us at any time if you wish us to cease communications and remove your personal information from our records.
Please note that if your personal information is shared with third parties (as detailed above) they may have different retention policies.
Keeping your information accurate
We strive to ensure that your personal information is kept up to date and accurate. If any of the personal information you have given to us or third parties changes, such as your contact details, please promptly inform us in accordance with the terms and conditions of your agreement with us.
You will be required to provide us with any changes to your personal information under the agreement you enter into with us if your application for a fertility plan is accepted. If you fail to do so this will put you in breach of your agreement.
How we monitor your communications
Subject to applicable laws, we will monitor and record calls, emails, text messages, social media messages and other communications. We will do this for the purposes of complying with applicable laws and regulations and our own internal policies and procedures, to prevent or detect crime, to protect the security of our communications systems and procedures and for quality control and staff training purposes.
What to do if you have concerns or want to make a complaint
If you have any concerns regarding our use of your personal information please notify our Data Protection Officer as soon as possible using the contact information set-out below. If we cannot resolve a complaint to your satisfaction you can contact the ICO at www.ico.org.uk or by telephoning 0303 123 113 if the complaint relates to the way your personal information has been handled.
Changes to our Privacy Notice
This Privacy Notice may be updated periodically at the Company’s discretion to reflect changes in our privacy practices or relevant laws. We will make any changes to this Privacy Notice by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This Privacy Notice was last updated on 19 August 2019.
How to contact us
If you have any questions in relation to the processing of your personal data, you should:
- Email us at email@example.com, or
- Telephone us on 0333 234 0895, or
- Write to The Data Protection Officer, Assured Fertility Ltd, PO Box 404, Alderley Edge, SK9 0EA.