CRGW Privacy Notice (GDPR)

CRGW Ltd PRIVACY NOTICE

CRGW (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

CRGW’s registered office is at Ely Meadows, Rhodfa Marics, Llantrisant, CF72 8XL and we are a company registered in England and Wales under company number 07029220. We are registered on the Information Commissioner’s Office Register; registration number A8362299, and act as the [data controller/data processor] when processing your data. Our designated Appointed Person is Ann-Louise Lane, who can be contacted at annlouiselane@crgw.co.uk.

CRGW processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site or correspond with us by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows: a. Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender. b. Contact Data which includes your billing address, delivery address, home address, email address and telephone numbers. c. Health Data which includes any information about your health including your medical history and/or current health status including but not limited to data regarding test results, diagnoses and medications. d. Financial Data which includes your bank account and payment card details e. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. f. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site. g. Profile Data which includes your username and password for any accounts set up to access our products and services, purchases or orders made by you, feedback responses. h. Usage Data which includes information about how you use our Site, products and services.

i. Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but does not directly or indirectly reveal your identity and so is not personal data in law. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. In order to provide you with our healthcare services, we may also collect Special Categories of Personal Data (as defined in GDPR) about you. This may include details about your race or ethnicity, religious beliefs, sex life or sexual orientation. We may also collect information about any criminal convictions and offences where we are under a legal or regulatory obligation to do so. 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We use different methods to collect data from and about you including through:

a. Direct interactions. You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us in person or by phone, e-mail or otherwise. This includes personal data you provide when you: • register to use our Site; • fill in our forms in person or over the telephone; • make a request for our products or services; • request marketing communications to be sent to you; • give us some feedback. b. Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites and apps employing our cookies Please see our cookie policy below. c. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers based inside and outside the EEA. d. Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services such as Lloyds Banking Cardnet Merchant Services based inside the EU.

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org.

CRGW takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

The lawful bases for processing personal data are set out in Article 6 of the General Data Protection Regulation (GDPR). We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data: a. Consent: you have given clear consent for us to process your personal data for a specific purpose. Please note that we do not rely on your consent as the lawful basis for processing including your personal data (including Special Category Data). This is because we are legally and ethically required to maintain certain records even if your consent is withdrawn (e.g. where we are required to maintain records by regulators / insurers). Where we do ask for your consent (e.g. to use our services and for marketing purposes to keep you informed of our services) we will do so to comply with the requirement to process personal data fairly, lawfully and transparently.

b. Contract: the processing is necessary for a contract we have with you (for example, to process and deliver goods or services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract. c. Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations). d. Vital interests: the processing is necessary to protect someone’s life. e. Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law. f. Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We also need to satisfy specific conditions for using your health data. We rely upon the following ground in this regard: g. Healthcare provision: the processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.

You have the right to access any personal information that CRGW processes about you and to request information about: –

• What personal data we hold about you

• The purposes of the processing

• The categories of personal data concerned

• The recipients to whom the personal data has/will be disclosed

• How long we intend to store your personal data for

• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

CRGW only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you want to exercise your rights regarding the processing of your personal data or are unsatisfied with how we have handled your information, you are able to contact us or the supervisory authority using the contact details below.

CRGW

Ann-Louise Lane

Ely Meadows, Rhodfa Marics, Llantrisant, CF72 8XL

01443 443 999 or annlouiselane@crgw.co.uk

The Information Commissioner Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

http://ico.org.uk/concerns/

We may have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party 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.

Examples of our third parties include: a. Sub-contractors for the performance of any contract we enter into with them or you; b. Service providers acting as processors who provide IT, system administration appointments and medical diagnostic services; c. Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services; d. Also, in accordance with law and regulation, we may be required to disclose your personal data with other medical practitioners such as the General Medical Council and HFEA.

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CRGW takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.

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. In the event that we identify a personal data breach that is likely to result in a risk to your rights and freedoms we will notify you and the ICO (information commissioners office) within 72 hours of the breach we will also comply with any direction given by the Human Fertilisation and Embryology Authority (HFEA).

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. CRGW may utilise some products or services (or parts of them) that may be provided by healthcare professionals in non-EU countries, which means that we may transfer information which is submitted by you outside the European Economic Area (“EEA”) to fulfil a contract for services for the below purposes: –

Healthcare provision: the processing of data concerning health is necessary for us to provide a medical diagnosis and/or healthcare treatment. Please contact us for a list of countries where we may send your personal data.

Any transfers of personal data to a third country or an international organisation shall only be carried out on documented instructions by CRGW; unless required to do so by Union or Member State law. Where such a legal requirement exists, the Processor shall inform the Controller of that legal requirement before processing. CRGW will always ensure that when your data is transferred to a third country there are adequate measures in place to safeguard your information.

You are not obligated to provide your personal information to CRGW, however, as this information is required for us to provide you with our services/deliver your products/legitimate interests, we will not be able to offer some/all our services without it.

CRGW only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

We also consider and observe our data retention requirements as set out under the Human Fertilisation and Embryology Act 1990.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.