Please check the relevant section below for further information about our processing activities:
We are the next generation fertility clinic who has reimagined fertility care - maximising your chances of pregnancy by bringing you the best experience possible.
World-class medical expertise, personalised human guidance, together with the latest technologies and our position at the forefront of AI fertility research – to make you feel cared for, confident and relaxed.
We’re here to help you create a life – and live yours.
Apricity offers the following services (hereinafter “the Services”):
Please note that at every step of your use of the Tools and the Services, including (i) receiving information about the Services, (ii) conducting your needs analysis and providing a custom quotation, and (iii) entering into a contract for the provision of the Services, you will be provided with specific information and may be asked to explicitly consent to the processing of your special categories of personal data (as described further below).
Please be aware that legal information and consent forms will be provided to you directly by the healthcare professionals, nurses, healthcare facilities, pharmacists, labs and other assisted reproductive technology related professionals and bodies concerning the services and data processing they operate.
The data controller responsible for processing your personal data for the purposes identified in section 5.1 below depends on where you are based:
Your local Apricity entity provides the Services to you in your local country. Apricity SAS owns the Tools and software which enables the local Apricity entities to deliver the Services to you. As such, your local Apricity entity (identified above) and Apricity SAS are joint controllers of your personal data processed solely for the purposes identified in section 5.2 below.
Therefore, the other health professionals are solely liable for those processing operations and for the collection of your consent relating to those processing operations and any medical treatment you may receive, and you should contact the other health professionals directly in relation to any queries you may have about their processing of your personal data.
IIn providing the Services and making the Tools available to our patients and their partners, we may process personal data and special categories of personal data about you. In addition, if you are an employee of a business and Apricity processes your personal data for business administration or business-to-business marketing purposes, we may process limited personal data about you.
We may collect, use, store and transfer the following types of personal data about you:
If you are an Apricity patient, or the partner of an Apricity patient, we may also collect, use, store and transfer the following special categories of personal data about you:
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 (e.g. to provide the Services and make the Tools available to you). 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.
APRICITY processes your personal data (and, in some cases, your special categories of personal data) for the following purposes:
Apricity also processes your personal data (and, in some cases, your special categories of personal data) for the following additional purposes:
Please note that the processing of your personal data may involve profiling that will help Apricity to provide you with the most appropriate and relevant content and Services. However, this profiling will not be used to make automated decisions.
Data Analysis and Research
Apricity uses pseudonymised, aggregated and/or anonymised information for health-related studies, research or evaluation in which Apricity will participate. The types of data which may be used for analysis and research purposes include details about a patient (e.g. age, cause of infertility, lifestyle), lab results (e.g. blood test results, hormonal levels), information about cycle planning, the cycle itself, the stimulation phase and egg collection (e.g. stimulation treatment, number of follicles, number of collected eggs), information about embryology and the embryo transfer, results of ultrasound scans, and details about the success or otherwise of a pregnancy.
Applicable data protection law defines ‘pseudonymisation’ as ‘the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information’. Information is anonymised where it does not relate to a person and it is impossible to identify a person from that data, and this type of information usually falls outside data protection laws.
This information is held securely by Apricity and will not be used to identify you individually (e.g. by your name).
The purposes for which Apricity will use this information are:
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:
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@example.com.
In relation to your use of the Services and our Tools, please be aware that the withdrawal of your consent will prevent us from providing the Services to you.
Withdrawal of your consent will not impede on the lawfulness of the processing of your personal data conducted up to the date of the withdrawal.
Business-to business contact information:
Where we process the personal data of our customers’, suppliers’ or partners’ employees for business administration purposes, we do so on the basis of our legitimate interests which we will always balance against those individuals’ rights and freedoms.
Where we process business contact data for the purposes of business-to-business marketing communications, we will do in accordance with the laws of the country in which your personal data is being processed. If you are based in Spain, we will only send business-to-business marketing communications where you have provided your prior opt-in consent for us to do so. If you are based in the United Kingdom, we may rely on the ‘corporate subscriber exemption’ under the Privacy and Electronic Communications Regulations (PECR) in order to send marketing communications.
Note on the corporate subscriber exemption in the UK
The corporate subscriber exemption allows us to send business-to-business marketing emails to corporate addresses without prior opt-in consent. However, where we do so, we will always provide you with the option to opt-out or unsubscribe from receiving such communications at any time. This exemption is balanced with your right to privacy, and we will always ensure that we respect and uphold these rights when using your personal data for direct marketing purposes.
APRICITY ensures that none of your personal data will be transferred to a non-authorised third party, without your consent.
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.
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.
In case you decide to not use our Services, your personal data will be kept for 1 year from the date that you tell us.
Please note that the Human Fertilisation and Embryology Authority (HFEA) requires us to retain certain records for at least 30 years after treatment. For any other personal data associated with your account, but not covered by the HFEA guidelines, this will be kept during your contractual relationship with APRICITY and then will be archived for a period of 7 years before it is deleted.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. For example, Usage details will be retained for as long as necessary for the relevant processing purposes.
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.
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: firstname.lastname@example.org.
Under certain circumstances, by law you have the right to:
In order to exercise your rights, please contact APRICITY by emailing our Data Protection Officer at email@example.com, 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.
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 ask you beforehand for your consent.
If you would like to provide feedback or if you have any questions or concerns, or if you would like to exercise your rights concerning your personal data, you can contact our DPO at the following address: firstname.lastname@example.org