Privacy Policy

November 2024

Here at The Natural Fertility Hub (TNFH), your privacy is our top priority. We’re committed to safeguarding your personal and sensitive information. This Privacy Notice outlines how we collect, use, store, and share your data in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. As a data subject, you have the right to understand how we handle your personal data. This policy provides clear information about our data practices, empowering you to make informed choices about your privacy.

We kindly request that you take a moment to review this policy. If you have any concerns or disagree with its terms, please refrain from using our services. We may occasionally update this policy, and we’ll notify you of any significant changes. Your continued use of our services after such notification signifies your acceptance of the updated policy. This policy covers our data practices for both healthcare services and products, including private services. It also applies to data collected through our website, patient management system, and video call systems.

TNFH Information: TNFH is committed to protecting the rights and privacy of individuals in accordance with European and Irish data protection legislation. TNFH shall lawfully and fairly process personal data about employees, patients, clients, and other stakeholders to achieve its mission and functions. Throughout this document, ‘we’, ‘us’, ‘our’ and ‘ours’ refer to TNFH.  Your information is held by the Company.

Queries and Complaints: If you are unhappy with the way we handle your personal data and wish to complain, or if you simply want further information about the way your personal data will be used, please contact us at the below: The Natural Fertility Hub, Glenroyal Shopping Centre, Maynooth, Co. Kildare or by email at info@thenaturalfertilityhub.com.

You have the right to lodge a complaint with the Data Protection Commission. To contact the Data Protection Commission, please use the following details: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28 or by email: info@dataprotection.ie

 Personal Data Breaches: TNFH will take all appropriate technical and organisational steps to safeguard and protect your personal data. In the unlikely event of a data breach, we will contact you in line with our legal obligations.

Personal details collected and processed: When you purchase one of our Services, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. If you provide us with your email address: we may use it to send information, unless you have told us not to do so. To fulfil our contractual obligations to you in order to provide the Services to you: We may process your personal data to fulfil our contractual obligation to you such as account management and other administrative purposes. We may be obligated to process some of your personal data to comply with applicable laws and regulations.

Health and medical information: When you use our website and use our Services, you are sharing information about your health, symptoms, treatments, consultations and sessions, medications, and procedures. We get this information directly from you. We collect information about your health, including:

  • General health and lifestyle
  • Symptoms, treatments and medications
  • Information obtained from the results of subsequent investigations or treatments you receive based on the advice of TNFH
  • Information supplied in respect of your menstrual cycle, lifestyle factors and symptoms
  • Consultations, like notes, recordings, and transcripts from teleconsultations
  • Consultations with our referral clinical service and ultrasound partners
  • Your willing disclosure or input of detail in any correspondence with our team

These interactions may be shared with our fertility advisors so that we can provide you with personalised and accurate healthcare, and so that we can provide a better experience.

Financial Information: If you make any payments on the website, your credit/debit card details are processed directly by a third-party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.

Technical information and analytics: We collect information (i) you give us; (ii) information from your use of our services or our website AND (iii) information provided to us by third parties. When you use our website, we may automatically collect the information where this is permitted e.g. Cookies For further details on information collected from our website, please refer to the Cookie Policy.

What we use your personal data for: The purposes for which we use your personal data and the legal grounds on which we do so are as follows:

  • Providing you with a service: We need your personal information to enter into a contract with you and deliver services.
  • We use your financial details to charge you if you use our paid service or buy our products. Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
  • We use your health and medical information to provide you with a healthcare service, including when it’s in your vital interests.

The health and medical information we use includes, but is not limited to:

  • Information supplied in our Fertility Assessment Call and Online questionnaire
  • Information obtained from your blood test results and semen analysis test results
  • Information relating to your health from our associate sonographers, nutritionists and acupuncturists
  • Information supplied in respect of your menstrual cycle, lifestyle factors and symptoms
  • Consultations, like notes, recordings, and transcripts from teleconsultations
  • Consultations with our referral clinical service and ultrasound partners
  • Your willing disclosure or input of detail in any correspondence with our team

Strict confidentiality and data security provisions apply. With your consent, we share this information with our associates. This is so we can give you the right care, including when it’s in your vital interests. These associates include:

  • Our associate nutritionists, fertility specialists or counsellors, if you use our teleconsultation service
  • Our associates and/or referral service partners e.g. sonographers, phlebotomists, nutritionists, acupuncturists, counsellors if you use in clinic appointments

We use your location to recommend services near you, like phlebotomy clinics or ultrasound facilities, if the services are available in your region.

Legal basis for processing your data: Under data protection law, TNFH must ensure that it has an appropriate lawful basis for the processing of your personal data and let you know what that basis is.  We will be processing your personal data based on the following lawful basis:

  • You have agreed or explicitly consented to the using of your data in a specific way
  • The use is necessary in relation to the services that you have entered into or will enter into, or will enter into (e.g., to provide you with laboratory services or because you have asked for something to be done)
  • The use is necessary because we have to comply with a legal obligation, regulatory authorities, and law enforcement
  • The use is necessary to protect your “vital interests” in exceptional circumstances
  • The use for our legitimate interests (which you may object to) such as managing our business including credit risk management, providing service information, conducting marketing activities, training and quality assurance, and strategic planning and the purchase or sale of assets

You can withdraw your consent to this processing at any time by emailing us at info@thenaturalfertilityhub.com.

How we store your personal data: We will take all steps reasonably necessary to ensure that personal data is treated securely in accordance with this Privacy Notice and the relevant law. In particular, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we manage, collect and store.

Who we share information with: When providing our services to you, we may share your information with:

  • Your authorised representatives.
  • Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii) you ask us to share your information.
  • Service providers who provide us with support services e.g. patient management systems providers
  • Statutory and regulatory bodies (including central and local government) and law enforcement authorities.
  • Our Associates, Your Healthcare professionals and TNFH Fertility Advisors.

When we engage another organisation to perform services for us, we may provide them with information including personal data, in connection with their performance of those functions. We do not allow third parties to use personal data except for the purpose of providing these services.

Your rights: You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

  • Right to access: Data subjects have the right to access their personal data. They are entitled to receive a copy of their data held by TNFH and other information about the processing, sharing and retention of their personal data. The right of access allows individuals to be aware of and verify the lawfulness of the processing.
  • Right to rectification: Data subjects have a right to have their personal data rectified where it is inaccurate or incomplete.  TNFH is committed to holding accurate data about data subjects and implements processes and procedures to ensure that data subjects can rectify their data where inaccuracies have been identified.
  • Right to erasure (right to be forgotten): Data subjects have a right to request the deletion or removal of personal data where there is no compelling reason for its continued processing. The right to erasure does not provide an absolute ‘right to be forgotten’. The data subject has the right to seek the erasure of their personal data by TNFH, where:
    • The personal data is no longer required for the purposes for which it was obtained.
    • The data subject has withdrawn consent and there is no other lawful basis for the processing.
    • The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
    • The personal data is being unlawfully processed.
    • The personal data requires deletion in line with legal requirements.
  • Right to restriction of processing: Data subjects have a right to block or suppress processing of their personal data in defined circumstances. When processing is restricted, TNFH is permitted to store the personal data, but not further process it. Data subjects have the right to restrict the extent of processing of personal data on receipt of a valid request.
  • Right to object: Data subjects have the right to object to:
    • Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
    • Direct marketing (including profiling).
    • Processing for purposes of scientific/historical research and statistics.
  • Right not to be subject to automated decision making: Data subjects have the right not to be subject to a decision based solely on automated processing, where such decisions would have a legal or significant effect concerning the subject. Automated processing includes profiling.
  • Right to withdraw consent: Data subjects have the right to withdraw their consent to the processing of their personal data at any time.
  • Right to lodge a complaint: See Queries and Complaints above.

Contact us

For any questions or concerns, you can contact us by sending an email to info@thenaturalfertilityhub.com.