Your privacy is important to us. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, DIA, and its associated services.
Personal information is any information about an identified or identifiable person. The personal information that you provide and we collect may include information about you as a person (such as name, date of birth and sensitive information about your health), your devices, and how you use an app or online service.
This policy is effective as of 31 March 2021.
Last updated: 4 March 2022
“The Fertility Partnership Ltd” (“TFP”, “our”, “us” or “we”), a company registered in England and Wales (company number 08765580) whose registered office is at Institute Of Reproductive Sciences, Oxford Business Park North, Oxford, OX4 2HW.
Information we collect falls into one of two categories: 'voluntarily provided' information and 'automatically collected' information.
'Voluntarily provided' information refers to any information you knowingly and actively provide us when using our app and its associated services.
'Automatically collected' information refers to any information automatically sent by your device in the course of accessing our app and its associated services.
When you access our servers via our app, we may automatically log the standard data provided by your device. It may include your device's Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Our app may access and collect data via your device's in-built tools, such as:
Background data refresh
Operating system and its version
Unique device identifiers
When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorised by law.
For the purposes of this policy, the sensitive information we use primarily includes:
Information about your physical or mental health, including the health and care services you receive
Information about your sex life
If you choose provide us with any other personal information, which by its nature is particularly sensitive and therefore subject to additional legal safeguards under data protection law, this will also be treated as sensitive information.
Sensitive information that you can voluntary provide includes:
Sleep (sleep quality, sleep time)
Exercise (exercise quality, exercise time)
Last Period (start/end/duration)
Polycystic Ovary Syndrome (PCOS)
Family planning ambition
Existing TFP patients can choose to connect to their clinic in the ‘My clinic’ section of the app to display this information on their mobile app:
Appointments (all past / future)
Drugs (all past / future)
You can also choose to import your personal information about your health and activities from third party services like Garmin and Fitbit into Dia. This may include data about your sleep, weight, water, and other data about your health. We will always ask for your consent before we process any personal information from these third party services.
Most of the personal information we process is voluntarily provided to us directly by you for one of the following reasons:
Emails and passwords are required for the security authentication process.
Personal and sensitive information is collected so you can track your health and receive insights into how your health changes over your cycle
Personal and sensitive information provided through a questionnaire is used for Fertility Forecast, an educational feature that helps women better understand their fertility based on the most recent research
We also receive personal information indirectly, from the following sources in the following scenarios:
If the you are an existing TFP patient you can connect portal information to My Clinic. We don’t duplicate data and we can’t edit it.We use this information in order to display your appointments and medications.
When we collect and process personal information, and while we retain this information, we will implement appropriate and proportionate measures to protect it to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
You are also responsible for keeping your personal information secure and you can take steps to minimise data security risks. You are responsible for:
Selecting any password and its overall security strength
Ensuring your password is unique (not used for any other services)
Keeping your password safe (not sharing it with third parties or storing it in a way that puts it at risk of loss, theft or unauthorised access)
Regularly updating your password especially if it may have been compromised
Ensuring the security of your own personal information within the bounds of our services. For example, ensuring you do not inadvertently provide or authorise us to collect personal information, and do not make make your personal information publicly available via our platform.
Your information is securely stored and encrypted in an Azure database. This is a secure cloud computing service provided to us by Microsoft. Your information is stored in the UK and the EU (see also ‘Disclosure of Personal Information to Third Parties ‘ and ‘International Transfers of Personal Information’ below).
We will generally keep your personal information for as long as you remain a registered user of the app, to enable us to provide the app and associated services to you.
If you have provided us with personal information such as an email address when contacting us about a specific enquiry, we may retain this information for the duration of your enquiry remaining open as well as for our own records so we may effectively address similar enquiries in future.
If your personal information is no longer required for such purposes, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information in accordance with the law for legal, accounting, or reporting reasons or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13.
The app uses the application monitoring and error tracking platform Sentry, which collects some device and usage information such as device model, operating system or API calls which took place during the occurrence of an error. This helps us to understand the overall stability of our app, identify bugs and prioritize fixes.
The personal information we collect is stored and/or processed in the UK and/or the EU.
If we transfer your personal information to another country outside of the UK and/or the EU or to an international organisation we will only do so in accordance with the law. This will include ensuring an adequate level of protection for your personal information and, where appropriate, implementing of appropriate safeguards to protect your personal information. You wish to obtain more information about this, please contact us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Your rights: you have the following rights in relation to your personal information:
Request access to your personal information – this enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you – 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.
Request erasure of your personal information – 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 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 the law.
Object to processing of your personal information – where we are relying on legitimate interests (see ‘Lawful Bases for Processing Your Personal Information’ below) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request restriction of processing of your personal information – this enables you to ask us to suspend the processing of your personal information in the following scenarios:
If you want us to establish the information’s accuracy
Where our use of the information is unlawful but you do not want us to erase it
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
You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party – we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that 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.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please contact us to exercise any of your rights. We will handle your request in accordance with the law and advise you of the action taken in response to your request and how you may make a complaint if you are dissatisfied with our response.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint. In the UK, the relevant organisation is the Information Commissioner’s Office.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of or object to, as applicable, any new uses of your personal information.
We will only collect and use your personal information when we have a lawful basis to do so. We will collect and use your personal information lawfully, fairly and in a transparent manner.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. This includes the Terms of Services in relation to the use of the App and associated services. For example, we need technical information about your device in order to provide the essential features of our app.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. For example, we collect technical information about your device in order to improve and personalise your experience of our app. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law
We do not take decisions regarding you, based solely on automated processing which produce legal effects concerning you or similarly significantly affect you.
For any questions or concerns regarding your privacy, you may contact us using the following details:
The Data Protection Officer of TFP
Name: The Fertility Partnership
Address: Institute of Reproductive Sciences,
Oxford Business Park North,
Alec Issigonis Way,
Oxford OX4 2HW.
Phone Number: 0808 196 1942