Become a donorLegalPrivacy Policy

    Privacy Policy

      


    At Cryos, personal data security is a top priority. It is important to us that we ensure the best possible protection of the personal data we process as well as the highest level of clarity and transparency in our personal data processing.

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    Regulation 2016/679 of the European Parliament and of the Council (hereinafter “GDPR”) came into force on 25 May 2018 and contains a number of new regulations for the processing and protection of personal data.

    In this privacy policy, you can learn how Cryos processes personal data collected via our website. The privacy policy applies to personal data that Cryos collects regarding

    • Visitors to our website
    • Our customers
    • Donor applicants
    • Job applicants

    DATA CONTROLLER

    Cryos International - Cyprus Limited (HE 381787), 1 Demofontos street, 1075 Nicosia, Cyprus (hereinafter “Cryos”) is the data controller for the personal data that is collected via Cryos’ website and processed for various purposes.

    We can be contacted by calling +357 22007656 or by email at [email protected]

    OUR DATA PROTECTION OFFICER

    If you have questions concerning how Cryos processes your personal data, you are always welcome to contact our Data Protection Officer at [email protected] or to call +35722377863.

    THE PURPOSE AND LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
    Personal data that we collect from visitors to our website

    When you use the site

    When you use Cryos’ website, we collect various data about you, including information on the pages you visit. For this, Cryos uses its own, as well as third-party, cookies in order to remember your settings, optimise the website’s functions, collect statistics and target our marketing.

    You can read more about how we process personal data collected using cookies in Cryos’ cookie policy

    The legal basis for processing personal data that Cryos collects using cookies is GDPR, Article 6(1)(f), as processing this data is necessary for Cryos to continuously optimise website functions and offer site visitors the best possible experience.

    When you create a user account

    If you want access to Cryos’ donor profiles and you are a private user, you must create a private user account. To be able to create your user account, Cryos collects personal data, such as your name, user name and your email address. Furthermore, you must register a password of your choosing. If you want access to Cryos’ donor profiles as a professional user, Cryos also collects data about the name of your company as well as its address and contact information.

    Cryos collects and uses the above personal data for creating user accounts and for protecting our donors’ personal data.

    The legal basis for processing data which we collect to create user accounts is GDPR, Article 6(1)(c) and (f), cf. Article 5(1)(f). Cryos’ requirement that a user account be created as a condition for accessing our donor profiles is necessary in order to ensure the best possible security for our donors’ data.

    Personal data that Cryos collects from our customers

    When you place an order with Cryos

    When you, as a customer, place an order on Cryos’ online shop, we collect personal data about you, such as your name, your birthday, as well as your contact and payment information in order to register, process and deliver your order.

    Furthermore, we process this data to use it in the ongoing administration of the customer relationship, which includes the ability to receive and respond to enquiries and to be able to contact you with important information, for example concerning the donor from which you have chosen to buy sperm,

    changes to the pregnancy quotas or changes to legislation etc. that are of relevance to your purchase or your reservations.

    The legal basis for this data processing is GDPR, Article 6(1)(b).

    Customer satisfaction surveys

    Furthermore, Cryos will use your email to contact you and ask if you want to participate in a customer satisfaction survey. This is done so that we can continue to optimise and change our customer service based on the responses in the surveys.

    The legal basis for this personal data processing is GDPR, Article 6(1)(f), as it is necessary for Cryos to run these customer satisfaction surveys in order to learn how our customers see us, and thus ensure continued high levels of customer satisfaction.

    Statistics and analysis, system development and error detection

    Cryos uses your personal data for statistics and analysis in order to develop, test and improve our products, services and systems and to be able to analyse trends and patterns with our customers. We aggregate and anonymise data as much as possible for these purposes.

    Cryos also uses your personal data in connection with ongoing development and error correction in our systems, including to adjust and optimise our services and products in order to provide a better customer experience.

    The legal basis for this personal data processing is GDPR, Article 6(1)(f), since the processing is necessary for us to carry out the tasks indicated above.

    Personal data that Cryos collects from donor applicants

    If you want to be a sperm donor with Cryos, you have to undergo a special application and selection procedure. The first stage in this procedure is that Cryos collects different information about you through an online application form found on our website, in which you answer a number of questions.

    This includes sensitive personal data such as information about your physical and mental health, your sexual behaviour, use of medication or other intoxicants, any tattoos and piercings as well as hereditary diseases in your family.

    Furthermore, Cryos collects ordinary personal data, including your contact information, your birthday and your responses to questions concerning a number of practical matters in connection with being a donor.

    Finally, Cryos collects any other information that you may want to share with us.

    Cryos collects and reviews sensitive information as well as information about your age in order to assess if you can become a sperm donor at Cryos, which includes determining if there is an indication of increased risk that you will develop serious illnesses or hereditary recessive diseases that may be transferred via your potential donations.

    We have chosen which data we collect, and we evaluate it in accordance with the criteria indicated in the relevant legislation, including the Cypriot the standards for quality and safety (Donation, Procurement, Testing, Processing, Maintenance, Storage and Distribution) Human tissues, cells and related products law [the law on human tissue and cells] (Law 187(Ι) of 2007), with the respective amendments (Law 146(I)/2014, Law 8(I)/2017).

    The legal basis for this processing of personal data is GDPR, Article 9(2)(a).

    Cryos collects your ordinary data, as well as any other information that you choose to share with us, in order to be able to contact you, register you in our database, know which department at Cryos you want to donate to, and learn more about your considerations in relation to becoming a donor.

    The legal basis for this processing of personal data is GDPR, Article 6(1)(a).

    As a donor candidate, you can always withdraw your consent for Cryos to process your personal data. You can do that by contacting our DPO, the details of whom can be found above in this privacy policy.

    If you withdraw your consent, we cannot carry out the necessary assessments concerning your health and we cannot consider your application to be a donor at Cryos.

    Withdrawing your consent will not affect the legality of the data processing that Cryos carried out on the basis of your previous consent and until the time when the consent was withdrawn. If you withdraw your consent, this decision shall therefore only be in effect from that time.

    Personal data that Cryos collects from job candidates

    When you apply for a position at Cryos, our online application system collects your name, contact information, application and CV as well as other personal data that you upload. The purpose of processing this data is to assess your suitability for the position to which you are applying.

    When you register with Cryos’ online Job Agent, Cryos also collects personal data that you upload to your profile, including name, contact information, unsolicited application, CV, information concerning job experience, language proficiencies, etc. This is to allow Cryos to automatically match your data with all current and future available positions at our company. If there is a good match, Cryos will send you a request to apply for the respective position.

    The legal basis for this data processing is GDPR, Article 6(1)(b) and (f), as collecting data about our job candidates is necessary for us to recruit the right person and the necessary new employees for our company.

    TO WHOM DOES CRYOS DISCLOSE YOUR DATA

    Data about our customers

    Cryos discloses your name, birthday and information on your address and order to the clinic to which you asked us to send your order, so that the clinic can identify you and manage the ensuing process.

    Cryos uses data processors that provide software tools that enable us to fix any errors or deficiencies on our website. The employees of our data processors will gain access to your personal data in order to be able to provide the tools we purchased. Additionally, we use providers of cloud solutions to store your data.

    Data on donor applicants

    Cryos uses data processors consisting of other companies in the Cryos Group. Employees in these companies gain access to and review your data in the donor application form in order to help us assess your suitability as a donor. Furthermore, Cryos uses a cloud provider to store your data.

    Information on job applicants

    Cryos uses an external provider as a data processor to provide the online recruitment solution to which you upload your data when you submit your application or register in our Job Agent. This provider also stores the applicant’s data for us.

    HOW LONG DOES CRYOS KEEP YOUR PERSONAL DATA

    User data for Cryos’ website

    Personal data, such as user name and email, collected when you register a user account on the Cryos site will be saved for 8 months from the time when your profile was last active.

    Data on Cryos’ customers

    If you are a customer who purchased donor sperm from Cryos, we have a legal obligation to keep your contact information and information about your purchase for at least 30 years from the time when sperm was last distributed from your selected donor, including if the donor’s sperm is distributed to a different recipient at a later time.

    The relatively long storage period is due to the fact that Cryos is under a legal obligation to ensure traceability of donor sperm during all phases, from donation to distribution to the recipient, in the specified period, in case hereditary diseases or other conditions happen to be discovered in the donor or the donor’s children later on.

    If you are a customer in a country other than Cyprus, national rules may apply for ensuring traceability which require Cryos to keep your data for more than 30 years from the latest time the sperm from your selected donor was distributed. In this case, the storage period will depend on any requirements in the relevant legislation that you are covered by.

    Due to the above, it is not currently possible to specify exactly how long we keep your data, just that the period will be determined based on the above criteria.

    Donor applicants

    If you become a donor with Cryos and your sperm is distributed to our customers, Cryos has a legal obligation to ensure traceability of your sperm in all phases, from donation to distribution to the recipient, for at least 30 years, in case hereditary diseases or similar are later detected in you or your children.

    We therefore keep identification data and certain other information about your donations for at least 30 years from the latest distribution of your sperm.

    If your sperm is provided to a customer in a different country than Cyprus, national rules for ensuring traceability may apply in the receiving country

    which necessitate that Cryos keeps your information for a period exceeding 30 years from the latest distribution of your sperm. In such cases, the storage period will depend on any requirements in the relevant legislation of the receiving country.

    Due to the above, it is not currently possible to specify exactly how long we keep your data, just that the period will be determined based on the above criteria.

    If you do not become a donor with Cryos, we save your data for 10 years from the time you got rejected to become a donor or chose to interrupt your application process.

    Job applicants

    If you are offered a position at Cryos, we keep your information as long as you are employed with us and for 6 years after termination of the employment.

    If you are not offered a position at Cryos, we keep your data for up to 6 months from the time when the position that you applied for was filled.

    If you have created a profile in Cryos’ Job Agent, we generally save your data for 6 months from the time you created the profile, after which it is deleted. If, prior to the end of this 6-month period, you indicate that you would like Cryos to keep your application for a longer period, we will keep your data for another 6 months.

    YOUR RIGHTS

    You have a number of rights that you can enforce in relation to how Cryos processes your data. These are described below:

    You have the right to be informed of the data that Cryos processes about you, and you have the right to access certain other information concerning how and why we process your personal data. This means that Cryos must provide a copy of the personal data we process about you

    • You have the right to correct incorrect data about yourself
    • In certain special cases, you have the right to have your data deleted prior to the point when Cryos would have deleted the data.
    • In certain cases, you have the right to limit the processing of your data. If you have the right to limit the processing of your data, from that point on Cryos may only process your data under special circumstances and for special purposes – with the exception of storage
    • In certain cases, you have the right to object to having your personal data processed by Cryos
    • In certain cases, you have the right to receive your personal data in a structured, commonly-used and machine-readable format and to have this personal data transferred from Cryos to a different data controller

    If you want to invoke your rights, you can contact Cryos, either by email [email protected] or by calling +35722377863.

    YOUR RIGHT TO LODGE A COMPLAINT WITH THE CYPRUS DATA PROTECTION AUTHORITY

    If you are not happy with the way Cryos processes your personal data, you can lodge a complaint with the Cyprus Commissioner for Personal Data Protection. You can find the contact information for the Cyprus Office of the Commissioner for personal data protection at www.dataprotection.gov.cy/

    At Cryos, we care about the privacy and security of your personal data and we take measures to ensure that your personal information is properly handled, whilst in our possession and in the possession of others, to whom we may disclose it, under the terms and for the purposes explained below in this Privacy Policy.

    This Policy explains when and why we collect personal data of our website visitors and about egg donor applicants and egg donors, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

    We may change this Policy from time to time. When we do so, we will notify you about the change by displaying a relevant notice on our homepage about the effected fact of the change and inviting you to visit this page, unless the amendment is a substantial one, such as an added data processing, in which case we will individually notify you of it. You are hereby called upon to check our website periodically, in order to keep up to date with any changes to our privacy policy. Importantly, by using our website, you agree to this Policy, as amended from time to time to the extent relating to information, we collect about you in your capacity as a user of our website. As far as information we are collecting about you, in the context of conducting our business, you are welcome to contact our DPO (see immediately below), in case you are not happy with any change to our Privacy Policy.

    In compliance with the law, specifically the EU General Data Protection Regulation (GDPR), our Company has appointed a Data Protection Officer (DPO), specifically, an external legal advisor. In case you have any questions regarding this Privacy Policy or any question or complaint as regards to how your personal data is handled, you can contact our DPO as follows:

    Name: Dr. Christiana Markou

    Email: [email protected]

    Tel.: 22377863, Fax: 22377860

    Address: 2, Amfipoleos street, Marcou Tower Office 201, 2025 Strovolos Nicosia, Cyprus.

    Who are we?

    Cryos International - Cyprus Limited, a company (HE 381787)

    Address: 1 Demofontos street, 1075 Nicosia, Cyprus.

    Tel: +357 22007656

    Email: [email protected]

    Website: https://eggdonor-cy.cryosinternational.com/

    How do we collect information from you?

    We obtain information about you when you use our website, for example, when you contact us about our services, if you register to receive information from us, if you submit to us an Online Application Form through our website, if you submit a complaint, if you submit any question or query.

    We may also record information about you while you use our website, even if you do not do any of the above, and simply browse through our website by clicking on links displayed on our website. Such information is automatically recorded in the server logs of our website and/or by cookies, as explained below in this Privacy Policy.

    We also collect information about you, offline, mainly through our assessment procedure, most commonly:

    1. when you submit to us an Application Form for being a donor,
    2. when you undergo the assessment and selection procedure,
    3. when you submit a complaint, a question, query or request to us,
    4. when you contact us or we contact you, for the purpose of you being assisted or supported in relation to an obligation, either yours or ours, arising from the Law or for purposes relating to the conclusion, execution or administration of the Donor Contract.

    What type of information is collected from you?

    The personal information we collect includes your name, username, identity card number or  passport, or drivers licence, date of birth, information about your education, business occupation, telephone number, address, email address, IP address, and information regarding what web pages within our website are accessed and when. We also collect any other information you provide to us by filling in and submitting web forms on our website or by filling in and send via email questionnaires.

    We also collect all personal data you are providing to us by filling in and submitting our online donor application form, as well as when you undergo a special assessment and selection procedure. This includes categories of sensitive (or special category) personal data such as information about your physical and mental health, blood samples resulting in data about your health, race and ethnic origin, genetic data resulting from mouth or cervical swap testing, lifestyle and sex life, use of medication or other intoxicants, any tattoos and piercings, hereditary diseases in your family, as well as biological, genetic and laboratory test results. We also collect information such as, your height, weight, hair colour, eye colour and all information shared or provided to us through an initial appointment information form and egg donor extended profile, your responses to questions concerning a number of practical matters in connection with you being a donor, all information provided through our egg donor consent form and the Human Fertilisation and Embryology Authority form, as well as by filling the relevant Clinical Examination Questionnaire and all information on the Zika and Ebola risk assessment form. We also collect your childhood or adult photos, your voice through a recording and your handwriting through a handwritten message.

    For a tabled and more detailed version of information regarding what pieces of personal data we collect, how we collect it, the purpose we do so and the parties to whom it may be disclosed, please click here.

    How and on what legal basis is your information used?

    We use your non-sensitive personal information lawfully, in accordance with,

    • Article 6(a), i.e., for purposes you have consented to,
    • Article 6(b), i.e., as necessary to conclude or perform a contract with you,
    • Article 6(c), i.e., to comply with obligations imposed by law (such as medically assisted reproduction legislation) and,
    • Article 6(f), i.e., as necessary for legitimate interests we pursue as a business.

    More specifically:

    Article 6(b)

    • respond to, examine or satisfy applications, claims and related requests or queries submitted by yourself in the context of discussing, concluding and performing a donor contract,
    • confirm your identity,
    • draft, issue and deliver to you, your donor contract,
    • carry out our obligations arising from any contracts entered into by you and us.

    Article 6(c)

    • comply with or respond to requirements or demands by regulatory authorities and comply with the Medically Assisted Reproduction Law of 2015 (Law 69(I)/2015), the Standards of Quality and Safety (donation, procurement, testing, processing, preservation, storage and distribution) of Human Tissues, Cells and Derivative Products Law of 2007 (Law 187(I)/2007), the Regulations adopted pursuant to these and other applicable laws as well as with tax legislation.

    Article 6(f)

    • notify you of any changes to our services or our privacy policy, if necessary,
    • carry out customer research, surveys and statistics having previously anonymized relevant data,
    • Organize our business efficiently, for example by avoiding re-examining a donor application we have previously rejected or we have already examined

    Article 6(a)

    • send you communications which you have requested such as a reply to a query or to inform you about the outcome of the examination of your Donor Application,
    • provide you with information regarding offers and our services, if you have specifically consented to such communications;
    •  

    We will not normally contact you for marketing purposes by post, email, or text message unless you have given your prior consent or in so far as is permitted by the law. You can change your marketing preferences and withdraw previously-given consent at any time or object to the processing of your information for marketing purposes by contacting our DPO, the details of whom are stated at the beginning of this Privacy Policy. In this case, we will stop sending you marketing messages. For further information regarding this right to object to the processing of personal data for direct marketing and in general, see below in this Privacy Policy.

    We use your sensitive personal information, such as data relating to your health, lawfully, in accordance with,

    • Article 9(2)(a), i.e., if you have given your explicit consent,
    • Article 9(2)(f),e., where necessary for the exercising and pursuing of legal claims.
    • Article 9(2)(i), e., for the protection against serious health threats and against the spread or inheritance of diseases by ensuring high standards of quality and safety of donated sperm or egg (through health-related tests) 

    If you need further explanation on how your information is used, you are welcomed to contact our DPO, the details of whom are stated at the beginning of this Privacy Policy.

    Where and how long we retain your information for?

    Your information is stored in physical (hard copy) files in our premises in Cyprus and also in electronic form in computer servers in Denmark. By way of exception, personal information in our corporate emails is stored by Microsoft in its own servers. Additionally, information we collect through our website is stored on servers situated in Denmark

    We only keep information for as long as it is necessary for us to perform a contract you have with us or to comply with legal obligations to which we are subject, namely by Cyprus Medically Assisted Reproduction and Donor Legislation and tax legislation.

    We retain your information for a period of up to 10 years, in case we have rejected a donor application submitted to us. This is to enable us to have a relevant history in our files so that we can take this rejection into account, in case you re-submit a relevant application to us in the future and take care to apply the minimization principle, i.e., we minimiza the retained data retaining only data necessary for said purpose. We retain information we collect about you in your capacity as a mere visitor to our website (in the server logs) for 90 days.

    If you become a donor with Cryos and your egg is distributed to our customers, Cryos has a legal obligation to ensure traceability of your egg in all phases, from donation to distribution to the recipient, for at least 30 years from the time of last clinical use on a recipient, in case hereditary diseases or similar are later detected in you or your children. We therefore keep your personal data, including sensitive data, for at least 30 years from the last clinical use of your egg.

    If your egg is provided to a customer in a different country than Cyprus, national rules for ensuring traceability may apply in the receiving country which necessitate that Cryos keeps your information for a period exceeding 30 years from the last clinical use of your sperm or egg. In such cases, the retention period will depend on any requirements in the relevant legislation of the receiving country.

    When there are no specified maximum retention periods, we retain your data for 10 years, starting from the date of the expiration of the contractual relationship with you or from the end or settlement of any dispute or claim that arises in relation to a donor contract. This 10-year retention period covers the period specified by the statute of limitations (which is six years) and the period that our external auditors advised us for tax purposes, (which is 7 years) and it is also in line with the maximum data retention period specified by the Data Protection Commissioner, in the case of banks. We may retain information relating to health, for up to 15 years, which is the maximum retention period specified by the Data Protection Commissioner for health data.

    Should the Cyprus Data Protection Commissioner specify any maximum retention periods, shorter or longer than the above, we will adjust our Policy accordingly.

    Storage of your personal data

     

    User Account Details

    Genetic data, data concerning health and other sensitive data

    Education and Occupation data

    Appearance Data

    Childhood and Adult Photos, Voice Recording, Handwriting

    Online identifiers

    Rejected Donors

    6 months

    6 months

    6 months

    6 months

    Not applicable

    90 days from last visit to our website

    Approved Donors

    30 years*

    30 years*

    30 years*

    30 years*

    30 years*

    90 days from last visit to our website

     

    Donor Children

    Not applicable

    30 years for approved Donors

    Not applicable

    Not applicable

    Not applicable

    Not applicable

    Donor Family Members/Spouse/Civil Partnership

    Not applicable

    30 years for approved Donors/5 years for rejected Donors

    Not applicable

    Not applicable

    Not applicable

    Not applicable

    Visitors on Cryos' websites

    Not applicable

    Not applicable

    Not applicable

    Not applicable

    Not applicable

    90 days from last visit to our website

     

    *This is so unless foreign laws apply requiring a longer traceability period as explained above

    Who has access to your information?

    We will never sell your information to third parties and we will not share it with third parties for marketing purposes.

    We may pass your information to our third party service providers, agents and subcontractors for the purposes of completing tasks and/or providing services to you on our behalf (for example to forward to you your contract or assist us in assessing a donor application submitted to us by you). Such third parties may also be technical service providers providing us with the software systems (or their maintenance) or cloud storage space necessary to contact administrative tasks inherent in the provision of our services to you or in the conducting of our business or messengers and/or delivery companies we use to deliver correspondence. We only disclose to them the personal information that is absolutely necessary to deliver the service or perform the task and when legally required, we have a contract in place that requires them to keep your information secure and in accordance with the principles and rules of the General Data Protection Regulation.

    Moreover, the recipients of personal data will mainly be companies in the Cryos Group and their employees or persons, who are processing data on behalf of the Company, the doctor and IVF host clinic staff, the Central test for the EQ test and to the extent permitted by applicable laws, the child if he/she requests it when he/she researches the age of 18 if the donor is ID release (i.e.,non-anonymous) as opposed to non-ID release (i.e., anonymous), natural persons who are interested in receiving and/or receive treatment with your eggs, the Cyprus Public and Private Maternity Units, UK IVF clinics, assessors or experts or other independent professionals, such as  doctors,  clinics, diagnostic centres, laboratories and psychologists , if required for the purpose of conclusion, execution and administration of the Donor Contract. We only disclose to them the personal information that is absolutely necessary for them to perform the relevant necessary tasks and when data sharing with them is large-scale or is otherwise legally required, we have a contract in place that requires them to keep your information secure and in accordance with the principles and rules of the General Data Protection Regulation.

    We may also pass your information to our lawyers and accountants/auditors to the extent necessary to defend or institute legal claims and to comply with legal obligations with regards to the preparation of financial accounts and tax reasons respectively.

    Finally, we may disclose your information to public and/or regulatory authorities, if disclosure is required by law or an order issued by a court of law.

    Here you can see a table showing potential recipients of your personal data as per the type of personal data and/or the medium.

    What are your rights?

    You may at any time, send us any of the following requests and we will meet them the earlier possible and in any case, within a month from the date of receipt of your request and inform you about the action we have taken. If your request is for any reason complex to examine or meet, we will ask you for an extension, before the aforementioned one-month period expires.

    If we have legitimate reasons to refuse to satisfy your request, we will inform you accordingly and in this case, you have the right to submit a relevant complaint to the Cyprus data protection authority, namely, the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy/) if you believe that our decision is unjustified.

    These are your rights and the relevant requests you can submit to us:

    A request that we permanently delete all or some of your information from our records (right to be forgotten or to erasure), for example, in case we no longer have reasons to have it.

    A request from you to access your information that we keep in our records (right of access)

    A request that we provide you with a copy of your information that exists in our records, in digital or hard copy form. If you require additional copies, we may charge you with a maximum of EUR 40,00 per copy, as administrative costs, depending on the volume of the data involved. (right to a copy)

    A request that we update or correct personal information that we keep in our records (right to rectification), for example, in case it is outdated or contains errors or inaccuracies.

    A request that we provide you with information of yours we keep in our records in a structured, commonly used and machine-readable format or forward it in such form to another provider of your choice, if such forwarding or transfer is technically possible (right to portability). Please note that this right applies only in relation to data that you yourself has provided to us with and which we process by electronic means, in the context of a contract between you and our Company or because you have consented to us doing so.

    A request that we stop doing anything with your information without however deleting it from our records (right to restriction of processing). In this case, we will restrict access to your personal data without deleting it if we are to satisfy your request.

    A request that we stop processing your information for direct marketing purposes or on the basis of legitimate interests pursued by our Company, as explained under the fourth question of this Privacy Policy by reference to Article 6(1)(f) or in the name of the public interest (right to object). In the case of direct marketing, we will stop processing your information. In the rest of the cases, we will do so the same unless we have compelling reasons to refuse to do so about which you will be informed within the relevant time-limit.

    In the case in which the decision as to whether you will be approved as a donor by our Company or not is taken solely on the basis of automated processing, you have the right to express an opinion on and dispute the decision, as well as to request that it be reviewed by a member of our personnel. Please note that for the time being such decisions are not taken solely on the basis of automated processing.

    If you wish to exercise any of the above rights, you will be able to do so by contacting our DPO at any of the contact details stated at the beginning of this Privacy Policy.

    Please note that before acting upon any of your above requests, we may require you to prove your identity, if we are in doubt about your true or correct identity. If we cannot identify you, we will inform you accordingly and we will not act upon your request.

    You have the right to submit a relevant complaint to the Cyprus data protection authority, namely, the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy/) if you believe that we do not handle your personal data in compliance with the Regulation.

    What security measures do we apply to protect your information?

    When you give us personal information, we take organizational and technical measures to ensure that it is kept secure and protected against unauthorized disclosure or access, alteration, accidental loss or other violation or unlawful processing. Such measures, amongst others, aim at restricting access to personal information, ensuring secure storage, limiting the risk of viruses and other harmful events, keeping secure back-ups and effectively destroying unnecessary data. These measures are listed in our Security Policy.

    Use of Cookies

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    Transferring your information outside European Union

    We may transfer your personal information to a country that is not a Member State of the EU in order to examine and/or process a donor application you may submit, such as to have laboratory tests performed or, in the future, in order to enable the use of your egg by an IVF clinic based outside the EU. If we have to transfer your personal information to a country that is not a Member State of the EU, we will make sure that your personal information will be given analogous and/or appropriate respect and protection, specifically by signing with parties based outside the EU, data sharing or a ‘controller-to-processor’ agreements that meet the requirements of the Regulation, particularly Article 46, if the country is one about which there is no EU Commission Decision of Sufficiency as per Article 45 of the Regulation or (in relation to the US), the non-EU party to receive your data is not  part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.