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    PRIVACY POLICY FOR EGG DONOR CANDIDATES AND EGG DONORS

    At Cryos your privacy and personal data security is our top priority. It is important for us to ensure the best possible protection of our donor candidates' and donors' personal data, and to ensure clarity and transparency regarding the different personal data processing operations relating to egg donation.

      In this Privacy Policy, you can find information about the following:

      1. When does this Privacy Policy apply?
      2. Who is the data controller for processing your personal data?
      3. Our Data Protection Officer
      4. Which personal data does Cryos collect?
      5. What is the purpose of our processing of your personal data?
      6. How long do we keep your personal data?
      7. To whom do we disclose your personal data?
      8. What are your rights?
      9. Who should you contact?
      10. Complaint guideline
      11. Amendments of the Privacy Policy

      1. When does this Privacy Policy apply?

      This Privacy Policy applies to Cryos' processing of personal data when you are a:

      • Egg donor candidate
      • Egg donor


      2. Who is the data controller for processing your personal data?
       
      Cryos International ApS, Company Registration Number 35 51 42 52, Vesterbro Torv 3, 5., 8000 Aarhus C, Denmark (hereinafter "Cryos" or "we") is the data controller for your personal data.

      3. Our Data Protection Officer 

      If you have any questions as to how Cryos processes your personal data, you are always welcome to contact our Data Protection Officer at [email protected] or by calling +45 8676 0699.


      4. Which personal data does Cryos collect?

      FOR EGG DONOR CANDIDATES:

      For candidates to our donor database, we will collect and process a range of personal data when you:

      • fill in a donor application
      • undergo initial screening, including answering health questions and having a physical and/or gynaecological examination
      • fill in and return our questionnaire
      • attend a clinical examination where you provide additional information, e.g. blood and urine samples and biometric data in the form of a numerical code used to identify your fingerprint and sign the donor agreement.

      You can read more about the different types of personal data and our purpose of processing such data in section 5.


      FOR EGG DONORS:

      When you have been approved as a donor with us, we will collect and process a range of personal data about you. This is when:

      • we collect data to be used for the description in a donor profile
      • you donate your eggs and submit blood and urine samples, notify us if you have been ill, or if there has been any changes in your risk behaviour since the last time you were examined in connection with a donation

      You can read more about the different types of personal data and how and for which purposes your data is processed in section 5.


      5. What is the purpose of our processing of your personal data?

      FOR EGG DONOR CANDIDATES:

      Your personal data is collected for the following two purposes:

      • to assess your suitability as a donor
      • to administrate you as a donor candidate with us.

      Information about you is collected in the following situations:

      INFORMATION THAT WE COLLECT WHEN YOU FILL IN A DONOR APPLICATION

      If you want to become a donor with Cryos, you have to undergo a special application and selection procedure. The first stage in this procedure is that you fill in an application form.

      When you fill in the application form, we will collect your name, date of birth, postcode, country and your contact information. We collect this information in order to administrate you as a donor candidate. Your application may be followed up with a phone call where we ask a number of preliminary questions to help clarify whether you can begin the selection process.

      The legal basis for this processing of personal data is:

      a) to take steps at your request prior to entering into an agreement with you (Article 6(1)(b) of the General Data Protection Regulation)
      b) to comply with our legal obligation to ensure safe donor identification (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation), and
      c) our legal obligation to collect and store certain data in order to assess and select donors (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) and Article 9(2)(b), (h) and (i) of the General Data Protection Regulation).

      INFORMATION THAT WE COLLECT WHEN YOU GO THROUGH THE SELECTION PROCESS

      As part of the selection process, you will need to undergo an initial physical and/or gynaecological examination and provide a blood sample that measures your level of the AMH hormone. You will be asked to fill in a questionnaire about your and your family's physical and mental health, your sexual behaviour, the existence of any hereditary or chronic diseases in your family, as well as data about your race and ethnic origin.

      In addition, you will have an interview with our psychologist before undergoing a clinical examination, where we record our observations about your physical health, height and weight, as well as characteristics such as eye colour and hair colour. You will also be asked a number of detailed questions regarding your and your family's behaviour and medical history. The purpose is to identify your personal risk behaviour and any hereditary diseases in your family.

      If you want to become an Early ID Release or ID Release Donor, you will be asked a number of detailed questions regarding your considerations of becoming an Early ID Release or ID Release Donor, and we register our assessment of your maturity level. The purpose is to ensure that you have given sufficient consideration to your choice of donor type.

      During the clinical examination, you will be asked to provide a new blood sample and a urine sample. These tests and samples will be tested for a number of hereditary and infectious diseases. You will receive information about the diseases you will be tested for. Based on the test results and the information provided by you during the selection process, an overall assessment will be made as to whether you can become an egg donor with Cryos.

      You are entitled to obtain information about the results of all tests and examinations together with a thorough explanation thereof. In all circumstances, Cryos will inform you if Cryos finds test results that show an abnormal condition that is important for your health, unless you prefer not to receive such information.

      This information is collected in order to assess your suitability as a donor with Cryos. The legal basis for the processing is your explicit consent (Section 15 of the Danish Health Act) and the compliance with our legal obligation to collect and store such data to be used for the selection of donors (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) and Article 9(2)(b), (h) and (i) of the General Data Protection Regulation).

      In addition to this information, we also collect your full name and civil registration number and a copy of your valid ID. The purpose and the legal basis for doing so is to ensure compliance with the requirements of legislation on record keeping (Chapter 1 of the Danish Executive Order on Record Keeping, cf. Article 6(1)(c) of the General Data Protection Regulation) and to ensure unambiguous identification of you and ensure traceability (Chapter 4 and 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation and Section 11(2)(1) of the Danish Data Protection Act).

      We will also collect your biometric data in the form of a numerical code used to recognise your fingerprint. The legal basis and the purpose for doing so is to ensure compliance with the requirements of legislation on ensuring unambiguous identification of you and ensuring traceability from the donor to the recipient (Chapter 4 and 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).


      FOR EGG DONORS:

      When you have been approved as a donor, some of the information collected from you when you were a donor candidate will now be further processed for new purposes, as described below.

      We will furthermore collect certain new information about you.

      Both the previously collected information and the new information will generally be processed for the following three purposes:

      • To describe you in a donor profile on our website
      • To assess your suitability as a donor
      • To administrate you as a donor with Cryos, including to ensure traceability of the donated eggs from the donation to the treatment of the recipient.

      In the following it is specified which information we process and for what purpose, and the legal basis for doing so.


      INFORMATION USED TO DESCRIBE YOU IN A DONOR PROFILE

      When you have been approved as a donor, we will collect certain new information about you, which we will use to describe you in our donor profile. Certain information that was previously collected in order to assess your suitability will also be used to describe you in the donor profile.

      The full donor profile will be available to clients who log in to our website by providing an email address or a mobile phone number and a one-time password.

      Furthermore, the profile will be disclosed to any future donor children conceived with your donated eggs.

      Which information is used for this purpose, and what is the legal basis for the processing?

      The following personal data will appear from the donor profile:

      • Donor type (Early ID Release, ID Release or Non-ID Release)
      • Profile type (Basic or Extended Profile)
      • Education and/or profession
      • Characteristics such as eye colour and hair colour
      • Height and weight
      • Donor number, allocated by Cryos

      The legal basis for such processing of information is the performance of the donor agreement entered into with Cryos (Article 6(1)(b) of the General Data Protection Regulation).

      The following previously collected sensitive information will be used to describe you in the donor profile on our website:

      • Race
      • Ethnicity
      • Blood type
      • Our evaluation of your psychological profile
      • Results of tests made for infectious and genetic diseases

      The legal basis for our use of this information to create a donor profile is your explicit consent (Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation). When the donor profile is completed by Cryos, the created profile is Cryos' property and will be published in our donor database on Cryos' website.

      Additional information collected from donors choosing to have an extended profile

      If you choose to be a donor with an extended profile, the following information will be collected and appear from the donor profile on our website:

      • One or several photos of you as a baby
      • Information provided by completing our "extended profile questionnaire"
      • A sound recording of your voice
      • Our staff's impression of you as a person
      • The result of an emotional intelligence test (EQ test)
      • Your religion
      • Any photo of you as an adult, that you may have chosen to submit to Cryos

      If you want to add photos of you as an adult to the donor profile, such information will be particularly protected so that only visitors to our website who are paying for access can obtain access to these photos.

      The legal basis for processing the photos you provide to us, the sound recording of your voice, our staff's impression of you and the other general personal data which you provide to us when completing the "extended profile form" is the performance of the agreement entered into with us (Article 6(1)(b) of the General Data Protection Regulation). See which information is collected via the "extended profile form" here.

      The legal basis for processing the EQ test, information about your religion and the other sensitive data collected via the "extended profile form" is your explicit consent (Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation). When the donor profile is completed by Cryos, the created profile is Cryos' property and will be published in our donor database on Cryos' website.


      INFORMATION USED FOR ASSESSMENT OF YOUR CURRENT SUITABILITY AS AN EGG DONOR

      The purpose of and the legal basis for processing your personal data
        
      As long as you are a donor with Cryos, we may ask you if you have been ill, or if there has been any changes in your travel or risk behaviour since the most recent examination. In addition, we may periodically take blood samples and ask you to provide a urine sample, which we will test for various infectious and hereditary diseases.

      The purpose is to ensure that you are a suitable donor at the time of the donation. The legal basis is compliance with our legal obligation to make an assessment of your suitability (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i), and Article 6(1)(c) of the General Data Protection Regulation).

      Once a recipient has been found for your donated eggs, the donation process begins with stimulation, monitoring and egg retrieval (see the patient guide for more information about the process). The purpose of this is to complete the egg donation.

      The legal basis for the retrieval of your eggs is your explicit consent (Section 21 of the Danish Executive Order on Human Tissue and Cells and Section 15 of the Danish Health Act) and compliance with the agreement entered into with you on egg donation (Article 6(1)(b) of the General Data Protection Regulation).

      We will use your donated eggs for scientific research if you have provided us with a separate consent in this regard. The legal basis for our use of your eggs for scientific research is your explicit consent (Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation).

      During the donation process, we process relevant health information and collect your full name and civil registration number. The purpose and the legal basis for doing so is to ensure compliance with the requirements of legislation on record keeping (Chapter 1 of the Danish Executive Order on Record Keeping, cf. Article 6(1)(c) of the General Data Protection Regulation) and to ensure unambiguous identification of you (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation and Section 11(2)(1) of the Danish Data Protection Act).

      Previously collected information

      When you have been approved as a donor, we will continue to store information that we have previously collected about you with the purpose at that time to assess your initial suitability as a donor. The purpose of the future storage is to document and ensure traceability as regards our compliance with legal requirements in relation to the suitability assessment in case a communicable disease is diagnosed in a person conceived using donor eggs from you and/or a legal claim is submitted against Cryos in this connection.

      The legal basis for our processing of this personal data therefore changes to the requirement to ensure traceability (Chapter 4 and Appendix 1, section E.1, of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (f), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).

      The DNA material from your blood and urine samples may be used for further examinations in order to uncover any other hereditary diseases in addition to those for which tests were run as part of your initial donor suitability assessment, including to determine your suitability as a donor either in general or in relation to a specific, potential recipient of your donated eggs:

      This may e.g. become relevant in the following instances:
       
      a) If a suspicion of you being a carrier of a specific genetic disease arises
      b) If a hereditary disease or a suspicion hereof is diagnosed in a child conceived by using your donated eggs
      c) If in connection with a genetic analysis in a child conceived by using your donated eggs, there are results that provide information about a significantly increased risk of other diseases (important health-related incidental findings)
      d) If a potential client wants to examine whether your donated eggs will be an attractive match with the client's own genetic profile (genetic matching)
      e) If a potential recipient of your donated eggs is aware that the recipient's male partner has a dominantly inherited disease, which makes it relevant by means of egg sorting (PGT) to examine whether the use of your donated eggs can take place without transfer of the dominantly inherited disease to the child.

      The legal basis for the processing is your explicit consent (Section 15 of the Danish Health Act and Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation), and in situation a) and b) above also compliance with our legal obligation to process and disclose information in the event of serious adverse reactions/adverse events (Chapter 6 the Danish Tissue Act and Chapter 7 of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) and (f) of the General Data Protection Regulation).

      Facial comparison (Cryos Face Matching)

      If you wish, we will collect a photo of your face. The purpose is to allow interested clients to examine to which degree their facial features resemble yours and thereby determine whether they think you are a suitable donor in terms of any specific requests regarding facial resemblance.

      The facial comparison is done by us by sending your photo to our supplier of the facial comparison service who will do the comparison when the client uploads a photo to the supplier. The comparison is performed by the tool registering and measuring specific facial features and structures and comparing these with corresponding facial features and structures in the photo uploaded by the client. The client will not be presented with the comparison itself but will only be informed of the degree to which there is a facial match between the client’s photo and one or more donors.

      It only takes a few seconds to do the comparison. The photo will be treated in confidence and will not be visible to the client. The photo will not appear from the donor profile and will in general not be disclosed to anyone outside Cryos apart from the supplier of the facial comparison service.

      The legal basis for processing this photo is the performance of the donor agreement entered into (Article 6(1)(b) of the General Data Protection Regulation).


      INFORMATION PROCESSED IN ORDER TO ADMINISTRATE YOU AS A DONOR, INCLUDING TO ENSURE TRACEABILITY FROM THE DONATION TO THE TIME OF TREATMENT OF THE RECIPIENT

      Your personal data

      Each egg donation is registered together with information about your name, date of birth and the date, location and time of the donation. This data is collected in order to ensure traceability and identification and to ensure traceability of the donation.

      The legal basis is compliance with our legal obligation to ensure a unique donor identification and traceability of the donated eggs (Chapter 4 and 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation).

      In order to pay compensation to you we will process your bank account information. The legal basis is performance of the donor agreement entered into (Article 6(1)(b) of the General Data Protection Regulation).

      We may need to use your phone number and your email address to contact you, e.g. to make an appointment to take mandatory blood samples or because we need to inform you about your test results. The legal basis for processing your contact information for this purpose is our legitimate interest in being able to contact you as a donor (Article 6(1)(f) of the General Data Protection Regulation).

      Your sensitive personal data

      At each examination and donation, we will identify you by using our fingerprint scanner to read your fingerprint. The legal basis and the purpose for doing so is to ensure compliance with the requirements of legislation on ensuring unambiguous identification of you and ensuring traceability from the donor to the recipient (Chapter 4 and 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).

      In case of a serious adverse reaction or an adverse event in connection with the use of your donated eggs, e.g., if any hereditary diseases are suspected or diagnosed in you or a child conceived by using eggs from you, we may process additional relevant health information about you and/or your family for the purpose of examining the serious adverse event/reaction.

      The legal basis for our processing of your health information in this connection is the need to comply with our legal obligations to process and disclose information in case of serious adverse reactions/adverse events (Chapter 6 of the Danish Tissue Act and Chapter 7 of Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).

      Your name and civil registration number

      Once you have become a donor, we will use your civil registration number or other relevant ID to ensure unique identification of you.

      The legal basis is compliance with our legal obligation, including to ensure full traceability of the donated eggs from the donation to the distribution to the recipient (Chapter 4 and 6 of the Danish Executive Order on Human Tissue and Cells, cf. Section 11(2)(1) of the Danish Data Protection Act.

      If you have chosen to be a donor with an Early ID Release or ID Release profile, we will furthermore store your name, your date of birth and the latest stated address provided by you, for the purpose of disclosing this information to the parents (solely applicable for Early ID Release) and/or any future donor children conceived using donated eggs from you.

      The legal basis is the donor agreement entered into (Article 6(1)(b) of the General Data Protection Regulation and Section 23(3) of the Danish Executive Order on Human Tissue and Cells) as well as Cryos' legitimate interest in complying with the agreement on disclosure of the donor’s identity to the parents and future donor children, and the legitimate interest of these persons to obtain information about your name, date of birth and address provided (Article 6(1)(f) of the General Data Protection Regulation).


      6. How long do we keep your personal data?

      FOR EGG DONOR CANDIDATES:

      If you do not become a donor

      Information collected about you during the application and selection process will be stored for ten (10) years after the most recent registration in your donor journal, pursuant to the requirements on keeping a medical record (Section 15(1) of the Danish Executive Order on Record Keeping, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).

      Blood and urine samples are destroyed by our partners no later than 7-14 days after the sample has been taken.

      FOR EGG DONORS:

      If you are approved as a donor

      We will store the information we have collected about you, including health information, for at least thirty (30) years from the most recent use of your donated eggs based on the requirements of the Danish Executive Order on Human Tissue and Cells on traceability and evaluation of serious adverse reactions that may occur with donor conceived children, and for documentation purposes.
                    
      If your donated eggs in a processed form (fertilised eggs) are distributed as part of the treatment of a recipient in another country than Denmark, the receiving country may have national rules to ensure traceability, which means that Cryos will have to store your information for a longer period than thirty (30) years from the most recent use of your donated eggs. Thus, the storage period will be determined on the basis of the receiving country’s national rules.

      We will store bookkeeping information for five (5) years after the end of the current financial year pursuant to the rules on documentation in the Danish Bookkeeping Act. This includes any information needed to document our bookkeeping, e.g., your banking information and documentation of compensation paid to you during your time as a donor.

      Blood and urine samples will be destroyed by our cooperation partners as soon as the required tests have been made, at the latest 7-14 days after the sample has been taken.

      Donated eggs will be stored only in connection with a current and imminent treatment of the recipient, or for research purposes if you have consented to this, but never longer than regulated by law, cf. the Danish Act on Artificial Insemination.


      WITHDRAWAL OF CONSENT

      To the extent where Cryos’ processing of your personal data is based on consent, you can withdraw your consent at any time. You can do so by sending an email to [email protected] or by calling us at +45 8676 0699.

      If you want to withdraw your consent, please note the following:

      A withdrawal of your consent does not affect the lawfulness of Cryos' processing of your information on the basis of your previously granted consent until the time when such consent is withdrawn. Accordingly, if you withdraw your consent, this will not take effect until from the time it is withdrawn.

      Withdrawal of consent can only be done until the time when the processing covered by the consent is carried out. Thus, you cannot withdraw your consent and stop the processing if the processing has already been carried out or completed.

      This means, for example, that you cannot withdraw your consent to the use of your information for the preparation of the donor profile when the donor profile has already been created and the preparation of the profile has been completed.

      Nor does a possible withdrawal affect Cryos' processing of data that we already process or can process further based on another legal basis, e.g. for the purpose of the performance of the donor agreement between you and Cryos, or to comply with our legal obligations, e.g. record-keeping or to ensure traceability of the donated eggs from the donation to the treatment of the recipient.

      Thus, whether the withdrawal of your consent means that your information is to be deleted will be determined on the basis of the actual facts at the time when you withdraw your consent and will also depend on the legal basis on which your information is processed.


      7. To whom do we disclose your personal data?

      Cryos’ staff is subject to a duty of confidentiality, and only staff with a work-related need to access your information may do so.


      FOR EGG DONOR CANDIDATES:

      Information that we process to assess your suitability as a donor

      Other companies in the Cryos Group will help us collect and analyse information we collect about you in connection with the application and selection procedure in order to help assess your suitability. We will store your data in an electronic database that is run and managed by another company in the Cryos Group.

      Furthermore, we use external service partners to perform the relevant tests and DNA extractions from your blood and urine samples. These test centres also store DNA material on behalf of Cryos. Cryos has entered into cooperation agreements, including data processing agreements, with these partners.

      FOR EGG DONORS:

      Your donations and information used by us for the description of you in our donor profile

      The donor profile will be available to everyone registering as a user on our website. This also includes persons residing in countries outside the EU/EEA.

      Below is a list of information that will be visible in the donor profile:

      • Donor number
      • Donor type (Early ID Release, ID Release or Non-ID Release)
      • Profile type (Basic or Extended Profile)
      • Education and/or profession
      • Characteristics such as eye colour and hair colour
      • Height and weight
      • Race
      • Ethnicity
      • Blood type
      • Our evaluation of your psychological profile
      • Results of tests made for infectious and genetic diseases

      For each assisted reproduction treatment involving your donated eggs, this information will be shared with the recipient of the treatment.

      If you have chosen to be a donor with an extended profile, the profile on the website can furthermore include the following information:

      • One or several photos of you as a baby and optionally a photo or video of you as an adult
      • Information provided by completing our “extended profile questionnaire”
      • A sound recording of your voice
      • A handwritten message
      • Our staff’s impression of you as a person
      • The result of an emotional intelligence test (EQ test)
      • Your religion if any

      Your information may be accessed by certain employees employed with other companies in the Cryos Group who help us store, collect and analyse information collected and continuously being collected about you in order to ensure, on an ongoing basis, your current suitability as a donor.

      Furthermore, we will share relevant and required information with other companies in the Cryos Group and external cooperation partners used by Cryos in connection with processing, distribution and administration of your donated eggs.

      Other processing and disclosure of your information in order to administrate you as a donor

      Serious adverse event or serious adverse reaction

      If a serious adverse event or serious adverse reaction is noted, including for instance if a communicable disease or a mix-up is noted, your donor number as well as information about the noted serious adverse event or serious adverse reaction, including potentially information about your health status, will be collected and disclosed anonymously to the health authorities and fertility clinics that may have received your donated eggs in processed form (fertilised eggs) as part of assisted reproduction treatment.

      The legal basis for such processing is our legal obligation to disclose such information (Chapter 7 of the Danish Executive Order on Human Tissue and Cells, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).

      Facial comparison

      If you have provided us with a photo of your face for facial comparison purposes, we will share your photo with the supplier of the facial comparison service. The supplier makes the comparison when a client wants to get her facial features compared to a donor's. Your photo will not be shared with the client, who will only be informed about whether the comparison service assesses that the facial features are similar or not.

      The legal basis for this processing is the facial comparison agreement concluded (Article 6(1)(b) of the General Data Protection Regulation).
       
      Disclosure of information to fertility clinics, national authorities, Donor Registries and donor children

      We may disclose information about you, including identifying information, to fertility clinics and relevant national authorities, including national donor registers, to the extent required pursuant to the legislation in the different countries and national obligations, or if it follows from instructions charted by competent, national authorities, which are applicable to the fertility clinics.

      In connection with distribution of the donated eggs in processed form (fertilised eggs) to the fertility clinics, we may disclose the information about you which appears in the donor profile on our website, including test results for infectious and genetic diseases. In some cases, if it is considered relevant for professional purposes, we may share excerpts of or entire test reports with the fertility clinics.

      If you have chosen to be an Early ID Release Donor, Cryos will disclose your name, date of birth and your latest stated address to the parents of the child, at the entitled person’s request once the child is born and until the child turns 18 years old. After the child has turned 18 years old, it’s solely the child itself who may request the information. The parents must demonstrate, or render probable with a significant level of certainty, that the donor conceived person has been conceived with eggs from you.

      In some countries, donor children and the children's parents may obtain certain information about you from the national authorities or clinics of each country before the donor child has turned 18 years.

      Which information to be disclosed and when will vary according to the legislation of each country. You will receive further information if relevant in relation to the distribution of your donated eggs in processed form (fertilised eggs).

      The legal basis for collecting and disclosing the information specified above is our legitimate interest in being able to contribute to assisted reproduction treatment of recipients in countries where the legislation so requires (Article 6(1)(f) of the General Data Protection Regulation) and the necessity of ensuring high quality and safety standards when distributing fertilised donor eggs as part of assisted reproduction treatment (Article 9(2)(i) of the General Data Protection Regulation).

      Further disclosure

      If we distribute your donated eggs to another company in our Group, we will furthermore disclose your personal data to this Group company. Your information will only be disclosed for the purpose of distributing your donated eggs and personal data for the purpose of medically assisted reproductive treatment or research if you have consented to this.

      To the extent where donated, processed eggs (fertilised eggs) from you have been distributed, as part of an assisted reproductive treatment, to a country outside the EU/EEA, this means that the above information may be disclosed to such a country outside the EU/EEA. If so, the legal basis for our transfer of your personal data to such a country will be Part V of the General Data Protection Regulation.

      Based on a specific request from our clients we may disclose information on whether a specific donor is still active, or whether additional donated eggs are expected to become available. Our clients request this information in order to assess the possibilities of more pregnancies with the same donor.

      On request by a client, we can inform the client of the donor's age at the time of donation if this information is necessary in connection with a current treatment (e.g. a nuchal fold scan).

      In some countries it is a legal requirement that the donor is alive at the time when the donated eggs in processed form (fertilised eggs) are distributed as part of an assisted reproduction treatment and/or at the time of treatment. When we distribute fertilised donor eggs to these countries, as part of an assisted reproduction treatment, we will check the civil registration number register in order to determine whether the said donor is alive.

      The legal basis for collecting and disclosing the information specified above is our legitimate interest in distributing fertilised donor eggs as part of an assisted reproduction treatment to countries where the legislation so requires (Article 6(1)(f) of the General Data Protection Regulation).

      In the event that Cryos no longer runs a tissue centre business, Cryos' prospective stocks of donated eggs and personal data subject to traceability requirements will be transferred to another tissue centre in accordance with the requirement specified in Section 11 of the Danish Executive Order on Human Tissue and Cells.


      8. What are your rights?

      You have certain rights available in connection with Cryos' processing of information about you. These rights are described below:

      • You have a right to access information which Cryos is processing about you and to obtain access to certain additional information about 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 obtain rectification of any incorrect personal data about you.
      • In certain situations, you have the right to obtain erasure of information about you before Cryos deletes it.
      • In certain situations, you have the right to limit the processing of your data. If you have the right to limit the processing of your personal data, Cryos may, going forward, except for storage, only process your data in special circumstances and for special purposes.
      • In certain situations, you have the right to object against Cryos' processing of your personal data.
      • In certain situations, you are entitled to receive the personal data provided by you in a structured, commonly used and machine-readable format and to transmit such personal data from Cryos to another data controller.

      If you want to make use of such rights, please contact Cryos by email at [email protected] or call us by phone at +45 8676 0699.

      9. Who should you contact?

      If you want us to update, rectify or delete the personal data we have registered about you, or if you have any questions to this Privacy Policy, please contact us here:

      Cryos International ApS
      Vesterbro Torv 3, 5.
      DK-8000 Aarhus 
      Phone +45 8676 0699
      Email: [email protected] 

      We will determine as soon as possible to which extent your request can be accommodated.


      10. Complaint guideline

      We hope that this Privacy Policy has provided you with the information you need.

      If you disagree with the way in which we are processing your personal data or the purposes for which it is processed, please contact us or our Data Protection Officer, which you can read about in section 3 of this Privacy Policy. You can also submit a complaint to:

      The Danish Data Protection Agency 
      Carl Jacobsens Vej 35
      DK-2500 Valby
      Phone +45 33 19 32 00 
      Email [email protected]


      11. Amendments of the Privacy Policy

      We reserve the right to amend this Privacy Policy due to significant changes in legislation, legal practice or our internal procedures.

       

      Updated 28 May 2026

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