Altrui Privacy Notice

Introduction

Altrui Ltd (“Altrui”) is committed to respecting and protecting your privacy.

When you contact Altrui you trust us with your information. This Privacy Notice is intended to help you understand what personal data we collect, why we collect it and what we do with it.

Our Privacy Notice explains:

• What personal data we collect and why we collect it.
• How we use that data.
• How we keep it secure.
• The conditions under which we may disclose it to others.
• The choices we offer, including how to access and update personal data.

You should read this Privacy Notice if you are an Altrui egg donor (“Donor”), an Altrui egg recipient (“Recipient”), the partner of a Donor or Recipient, or if you visit our website at https://www.altrui.co.uk/ (“Website”). Donors and Recipients also include prospective egg donors and recipients, such as individuals who submit a registration form or other enquiry to us but do not progress to the egg donation matching stage.

Who are we?

Altrui specialises in finding, matching, and looking after altruistic egg donors in the UK (“the Services”). Altrui Ltd is a company organised and existing under the laws of England, having its registered office at 1 Chapel Street, Warwick, United Kingdom, CV34 4HL, and registered with Companies House under number 07240881.

Our Data Protection Officer (“DPO”) is responsible for overseeing questions in relation to this Privacy Notice. You can contact our DPO at any time by emailing [email protected], concerning any and all questions related to your personal data or this Privacy Notice.

How do we collect information from you?

We obtain personal data about you when you use our Website, when you contact us directly to enquire about our Services, or register with us as a Donor or Recipient for egg donation, or if you choose to receive information from us, such as our newsletter.

What type of information is collected from you?

Donors and Recipients

In providing the Services to Donors and Recipients, we may process personal data and special categories of personal data about you and your partner. This information is collected from you directly.

We may collect, use, store and transfer the following types of personal data about you and, in some circumstances, your partner:

• Identity details, including your first name, last name, maiden name, date of birth, place of birth, marital status, physical characteristics, and photographs;
• Contact details, including your email address, telephone numbers, and home address;
• Profile details, including details about current children, family history, occupation, education history, interests/hobbies, description of personality, and responses to personal profile questions (in the case of Donors);
• Transaction details, including details of Services you have purchased from us, and payments received from you;
• Financial details, including bank account information;
• Marketing and communications details, including your preferences in receiving marketing from us and your communications preferences. We also gather statistics around email opening and clicks to help us monitor and improve our e-newsletter.

We may also collect, use, store and transfer the following special categories of personal data about you and, in some circumstances, your partner:

• Data concerning your health, including details of your medical history, fertility treatment history, and general health condition;
• Data concerning your sex life including details of contraception;
• Personal data revealing your racial or ethnic origin including your ethnicity and the ethnicity of your parents.

Website Visitors (including Donors and Recipients)

Some data is automatically collected about your equipment, browsing actions and patterns as you interact with the Website. We obtain such data through the use of cookies and similar technologies. Please see our Cookie Notice for further details.

We may collect, use, store and transfer the following types of personal data about you when you visit our Website:

• Technical details, including IP address, geographical location, browser type and version, operating system, and other technology on the devices you use to access the Website;
• Usage details, including information about how you use the Website, such as referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use.

What is our lawful basis for processing your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you – i.e. our contract to provide the requested Services to you.
• Where we need to comply with a legal obligation.
• Where you have provided your consent – e.g. to send you email newsletters.
• Where we have a legitimate interest and consider that your interests and fundamental rights do not override those interests – e.g. to respond to enquiries submitted via the Website.
• In the case of special categories of personal data, where you have provided your explicit consent.

Please note that where you have given us your consent, you can withdraw your consent at any time. In the case of email newsletters, you can opt out of these by unsubscribing or emailing us at [email protected].

In relation to your use of the Services, please be aware that the withdrawal of your consent will prevent us from providing the Services to you. Please also note that withdrawal of your consent will not affect the lawfulness of the processing based on consent before its withdrawal.

What happens if I fail to provide personal data?

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 (i.e. to provide the Services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

How is your personal data used?

We may use your personal data (and, in some cases, your special categories of personal data) for the following purposes:

• Send you information that you have requested from us.
• Process applications to become an egg donor or egg recipient.
• Provide the Services to you.
• Carry out our obligations arising from agreements entered into by you and us. For instance, passing some non-identifying information between Donor and Recipient and making referrals to Licensed Treatment Centres and Clinics for egg donation treatment.
• Send you communications which you have requested and that may be of interest to you. These may include information about our Services, upcoming events, newsletters, and other relevant activities.
• Dealing with requests to attend an event or entries into a competition.
• Seek your views or comments on the Services we provide.
• Notify you of changes to our Services.
• To establish, exercise or defend any legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• To obtain or maintain insurance coverage, manage risks, or obtain professional advice.
• To comply with legal or regulatory requirements.

Who is your personal data shared with?

We will not sell or rent your information to third parties.

Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes unless you have requested us to do so.

We may share and disclose your personal data with the following categories of third parties for the purposes described in this Privacy Notice:

• With your permission, we will pass your information to Licensed Treatment Centres for the purposes of fulfilling our Services and to enable egg donation treatment to proceed. We will also share your personal data with Apricity, our sister company, where you become an Apricity patient and engage them to provide fertility services to support your egg donation treatment.
• We may disclose your personal data to our service providers who perform functions on our behalf, insofar as it is reasonably necessary to provide specific services (including providers of cloud-based hosting, email marketing, social media management, and web analytics).
• We may be required to release your information to government regulators, such as the Human Fertilisation and Embryology Authority (HFEA), or to other third parties if we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
• Information may be shared with any member of our group of companies (including our ultimate holding company and all of its subsidiaries) insofar as reasonably necessary for the purposes set out in this Privacy Notice. This may include internal administration purposes as well as the provision/sharing of IT services or data centres within the group.
• We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• We may share personal data with third parties to whom we choose to sell, transfer or merge part of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

How long will your personal data be kept?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we kept 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.

Please note that the Human Fertilisation and Embryology Authority (HFEA) requires us to retain certain records for at least 30 years after treatment.

Marketing

If you want to receive our free donor newsletter then you can tick the relevant subscription box situated on the form on which we collect your registration information or use the subscription box on our website. Each newsletter provides the option for you to unsubscribe at any time.

Other than where you have asked us to (e.g. to send you our donor newsletter), we will not contact you for marketing purposes.

However, we may contact you from time to time to seek your views or comments on the Services we provide or to notify you of changes to our Services. If you would prefer not to be contacted for these purposes then please email us at [email protected].

How do we secure your personal data?

We have put in place appropriate technical and organisational 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.

International Transfers

Where personal data is shared and disclosed as set out above, these parties may be established outside the United Kingdom. For example, some of the service providers we use to support the Services are based in the US, and this would involve a transfer of your personal data to the US. Whenever we transfer your personal data outside the United Kingdom, we ensure that a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented where necessary. This may include, where appropriate, signing up to Standard Contractual Clauses. To find out more information regarding the specific mechanism used by us when transferring your personal data outside the United Kingdom, please contact us via email: [email protected].

What are your rights concerning your personal data?

Under certain circumstances, by law you have the right to:

• Access your personal data, including data inferred from profiling;
• Correct any mistakes to your personal data;
• Erase your personal data, in certain situations;
• Apply restrictions on our processing of your personal data;
• Object at any time to processing of your personal data for direct marketing;
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal data;
• Obtain an electronic copy of your personal data (right of portability);
• Withdraw your consent to our processing of your personal data, where we have collected and processed your personal data with your consent. Please note, however, that where you withdraw your consent this will limit our ability to provide the Services;
• Make a complaint to your supervisory authority. In the UK, this is the Information Commissioner’s Office (www.ico.org.uk).

In order to exercise your rights, please contact Altrui by emailing our Data Protection Officer at [email protected], attaching a copy of your identity document. We may need to request further information from you to help us confirm your identity. 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.

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 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.

Links to other websites

Our Website may contain links to other websites run by other organisations. This Privacy Notice applies only to our Website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Website.

In addition, if you linked to our Website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Changes to this Privacy Notice

We keep this Privacy Notice under regular review and may change it from time to time so please check this page occasionally to ensure that you are happy with any changes. In the event of a change in the way we process your personal data, we will notify you in advance or, if applicable, we will seek your prior consent.

This Privacy Notice was last updated in April 2021. Please contact us if you would like to access a previous version.

How to contact us

Any questions regarding this Privacy Notice and our privacy practices should be sent to our Data Protection Officer by email to [email protected].

If you change email address or telephone number, or you believe that any of the other information that we hold about you is inaccurate or out of date, please contact us as soon as possible and let us know about the changes so that we can update our records.