- Key terms
- Personal information we collect about you
- How your personal information is collected
- How and why we use your personal information
- Who we share your personal information with
- Where your personal information is held
- How long your personal information will be kept
- Transferring your personal information out of the EEA
- Your rights
- Keeping your personal information secure
- How to complain
- How to contact us
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (EU) 2016/679 (commonly known as the “GDPR”), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of those laws.
- Donors and donor applicants
- Visitors to our website
2. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
|we, us, our||KMT Aphrodite Egg Bank LTD (trading as Aphrodite Egg Bank) with registration number HE 435747. Our clinic is located at 8 Karaoli & Byron Corner, “Anemomylos” Building, Office No. 201, Nicosia 1095.|
|personal information||Any information relating to an identified or identifiable individual.|
|special categories of personal information|
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union
Genetic and biometric data.
Data concerning health, sex life or sexual orientation.
3. Personal information we collect about youWe may collect and use the following personal information about you:
- first name and last name
- date of birth and gender
- information that enables us to check and verify your identity, such as your identity card number or passport
- contact details, which includes your home address, email address and telephone number
- marriage status
- medical background
- genetic data
- blood test results, genetic test results and laboratory test results
- financial data, including billing and payment card details and details about payments you make to us
- patient feedback and treatment outcome information
- details of any communication you have with us
- information about complaints and incidents
- information relating to your use of our website
4. How your personal information is collectedWe collect most of this personal information directly from you—in person, by telephone, by any forms or applications that you fill in or email and via our website. However, we may also collect information:
- from publicly accessible sources;
- via other doctors and clinics
5. How and why we use your personal informationUnder 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, where your interests and fundamental rights do not override our interests or those of a third party;
- where you have given your consent;
- for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health care or treatment; or
- for reasons of public interest in the area of public health, such as protecting against serious threats to health or ensuring high standards of quality and safety of health care.
What we use your personal information for
Type of information
Lawful basis for processing
To provide our services and medical treatment to you including: (a) carrying out genetic, blood tests (b) assessing your suitability to become a donor (c) taking a decision as to the treatment most suitable for you (d) carrying out a medical diagnosis (e) preserving eggs and sperms (f) manage payments, fees and charges (g) collect and recover money owed to us
(a) first name and last name (b) contact details (c) date of birth and gender (d) information that enables us to check and verify your identity, such as your identity card number or passport (e) marriage status (f) medical background (g) genetic data (h) blood test results, genetic test results and laboratory test results (i) financial data, including billing and payment card details and details about payments you make to us
(a) Performance of a contract with you or to taking steps at your request before entering into a contract (b) Necessary for our legitimate interests (record and administer the services and treatments we provide, identifying suitable donors) (c) Necessary to comply with our legal and regulatory obligations (d) Your explicit consent, as far as special categories of data are concerned (e) for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health care or treatment (f) for reasons of public interest in the area of public health, such as protecting against serious threats to health or ensuring high standards of quality and safety of health care
To manage our relationship with you which will include: (a) Notifying you about changes to how we operate our business or the way we deal with you (b) Updating the information we have about you (c) Asking you to leave a review or take a survey
(a) first name and last name (b) contact details
(a) Performance of a contract with you or to taking steps at your request before entering into a contract (b) Necessary to comply with our legal and regulatory obligations (c) Necessary for our legitimate interests (to inform you about our practice, keep our records updated and to study how patients respond to treatments)
To run, administer and protect our business which will include: (a) Ensuring business and medical policies are adhered to, (b) operational reasons, such as improving efficiency, training and quality control (c) preventing and detecting fraud (d) preventing unauthorised access and modifications to systems (e) statistical analysis to help us manage our business, e.g. in relation to our financial performance, patient base, services and treatment range or other efficiency measures (f) Ensuring safe working practices, staff administration and assessments (g) To run and improve our website and ensure an optimal experience for our website visitors
(a) first name and last name (b) contact details, which includes your home address, email address and telephone number (c) financial data, including billing and payment card details and details about payments you make to us (d) patient feedback and treatment outcome information (e) information about complaints and incidents (f) details of any communication you have with us (g) information relating to your use of our website
(a) Necessary for our legitimate interests (for running, administering and protecting our practice, monitoring and improving our practice, making sure we are following our own internal procedures and working efficiently, preventing and detecting fraud and unauthorised access and modifications to systems) (b) Necessary to comply with our legal and regulatory obligations (c) For reasons of public interest in the area of public health, such as protecting against serious threats to health or ensuring high standards of quality and safety of health care.
Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities or external audits and quality checks
(a) first name and last name (b) contact details, (c) financial data (d) medical background, when required we are required by law to make disclosures to regulatory authorities.
(a) Necessary to comply with our legal and regulatory obligations (b) Necessary for our legitimate interests (for protecting our rights and defending ourselves in the context of audits, enquiries or investigations administration)
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Who we share your personal information withWe routinely share personal information with:
- service providers such as payment service providers;
- other third parties we use to help us run our business, e.g. website hosts;
- professional advisers including lawyers, consultants and auditors who provide legal, consultancy and auditing services to us; and
- our banks.
7. Where your personal information is heldInformation may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
8. How long your personal information will be kept
Due to the sensitive nature of the services we provide and the strict regulatory and legal frameworks with which we need to comply, it is not currently possible to specify exactly how long we keep your data.
Different retention periods apply for different types of personal data.
For example, if you become a donor and your sperm or egg is distributed to other patients, we have a legal obligation to ensure traceability of your sperm or egg in all phases, from donation to distribution to the recipient, for at least 30 years from the time of last clinical use on a recipient, in case hereditary diseases or similar are later detected in you or your children.
We therefore keep identification data and certain other information about your donations, including special categories of data, for at least 30 years from the last clinical use of your sperm or egg.
If you do not become a donor, we will usually keep your data for 5 years from the time you submit your donor application.
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 requirements.
In all cases, we will not retain your personal data for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal data, we will delete it or anonymise it so that it can no longer be associated with you.
9. Transferring your personal information out of the EEATo deliver our services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our service providers located outside the EEA;
- if you are based outside the EEA; and
- where there is an international dimension to the services we are providing to you
- We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
- Where we transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information by the European Commission, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.
The right to be provided with a copy of your personal information.
The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
To be forgotten
The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information 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 information 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 information to comply with local law. Note, however, that we may not always be able to comply with your re
Restriction of processing
The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. 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.
The right to object to processing of your personal information 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 information 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.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consent at any time where we are relying on consent to process your personal information. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’;
- let us have enough information to identify you;
- let us have proof of your identity; and
- let us know what right you want to exercise and the information to which your request relates.
You will not have to pay a fee to access your personal information 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 may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may 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.