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:
- Donor candidate
- 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, 5th floor, DK-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 DONOR CANDIDATES:
For candidates to our donor database, we will collect and process a range of personal data when you:
- fill in the sperm donor application and make an appointment for an initial sperm sample
- hand in your sperm sample
- 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 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 sperm and blood and urine samples, notify us if you have been ill, or if there has been any changes in your risk behaviour since your last donation
- you fill in any country-specific forms or consents in connection with your sperm being distributed to countries with specific requirements in this regard.
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 DONOR CANDIDATES:
Your personal data is collected for the following two purposes:
- To assess your suitability as a sperm 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 THE SPERM DONOR APPLICATION AND MAKE AN APPOINTMENT FOR COLLECTION OF INITIAL SPERM SAMPLE
If you want to become a sperm donor with Cryos, you have to undergo a special application and selection procedure. The first stage in this procedure is that you fill in a sperm donor application and make an appointment for collection of initial sperm samples.
When you fill in the sperm donor application and make the appointment, we will collect your name, date of birth, address, your e-mail and information about your appointment. We collect this information in order to administrate you as a donor candidate.
In addition, we will ask for your height, weight, eye color, hair color and your ethnic origin. This information is included in our overall assessment of your suitability as a sperm donor at Cryos.
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 (Part 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation).
c) our legal obligation to assess your suitability as a donor (Chapter 6 of the Danish Executive Order on Human Tissue end Cells, cf. the General Data Protection Regulation, Art. 9 (2)(b), (h) and (i) and Article 6 (1)(c)).
INFORMATION THAT WE COLLECT WHEN YOU SUBMIT YOUR INITIAL SPERM SAMPLE
When you show up for the initial sperm test, we collect your full name and CPR number. The purpose of this and the legal basis is to comply with the legal obligation to keep a medical record (Chapter 1 of the Executive Order on Record Keeping, cf. Article 6(1)(c) of the General Data Protection Regulation and ensuring secure 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).
The purpose of collecting the sperm sample is to determine its quality, including volume, concentration of sperm cells and the amount of motile sperm cells.
The legal basis for the extraction of the sperm sample and the processing of your analysis result 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 our legal obligation to assess your suitability as a donor (Chapter 6 of the Danish Executive Order on Human Tissue end Cells, cf. the General Data Protection Regulation, Art. 9 (2)(b), (h) and (i) and Article 6 (1)(c)).
The results are registered with your name, date and the time when the sample was submitted, all in order to ensure identification and effective administration of the sperm sample and you as a donor candidate.
The legal basis for this processing of personal data is our legal obligation to ensure safe donor identification (Part 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation).
INFORMATION THAT WE COLLECT VIA OUR QUESTIONNAIRE
If the result of the sperm sample is satisfying, we will ask you to fill out a questionnaire.
Your personal data
On the basis of your reply to the questionnaire, we process a number of general information about you. This information is collected for the purpose of assessing your suitability as a donor at Cryos.
The legal basis for the processing of this information is your explicit consent (Section 15 of the Danish Health Act) and the compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (Chapter 6 of the Danish Executive Order on Human Tissue and Cells, cf. Article 6(1)(c) of the General Data Protection Regulation).
Your sensitive personal data
On the basis of your reply to the questionnaire we will process sensitive data about you 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 and your risk behaviour in general. This information is collected in order to assess your suitability as a donor with Cryos.
The legal basis for the processing of such data is your explicit consent (Section 15 of the Danish Health Act) and the compliance with 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 9(2)(b), (h) and (i) and Article 6(1)(c) of the General Data Protection Regulation).
INFORMATION THAT WE COLLECT IN CONNECTION WITH THE CLINICAL EXAMINATION
If we still consider you suitable as a sperm donor after having reviewed your reply to our questionnaire, you will be invited to a clinical examination.
When you show up for the clinical examination, we collect your full name, CPR 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 ensuring unambiguous identification of you and ensuring 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).
We will register our observations regarding your physical health, your height and weight, as well as characteristics such as eye color and hair color.
We will take a blood test, and you must hand in a urine sample, which will be tested for a number of hereditary and infectious diseases.. You will receive information about which diseases you will be tested for.
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. When taking the blood test and running the analysis, we collect your CPR number to be able to register and display relevant test results at your medical journal at Minsundhed.dk.
After the clinical examination we will do an assessment of your psychological profile e.g., via a psychosocial interview. In addition, you will 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.
Based on the clinical examination, the psychological assessment, your test results and the information provided by you earlier in the approval process, an overall assessment will be made of the risk of transferring hereditary diseases that may occur in your family, which we will use to determine whether you can become a sperm donor with Cryos.
The legal basis for the processing of above information 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 the compliance with our legal obligation to collect and store such data to be used for the selection of donors (Chapter 6 and clause 3.6 in Appendix 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 and Section 11(2)(1) of the Danish Data Protection Act).
Extraction of sperm donations
If, during the clinical examination, no evidence is found for excluding you as a donor, the extraction and donation of your sperm will begin for the purpose of distributing the sperm for fertility treatment as well as for research purposes, if you have explicitly consented thereto.
The legal basis for the extraction of the sperm is your explicit consent (Section 21 of the Danish Executive Order on Human Tissue and Cells, and Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation).
FOR DONORS:
When you are 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 sperm donor on an ongoing basis.
- To administrate you as a donor with Cryos, including to ensure traceability of the donated sperm from the donation to the distribution to 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 the donor profile.
The complete donor profile will be available to everyone registering as a user on our website by entering an email address, a username and a password, and verifying their information via a link in a confirmation email.
Furthermore, the profile will be disclosed to any future donor children conceived with your sperm.
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 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 for creating a donor profile is your explicit consent (Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation). When creation of 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 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 and/or video recordings you provide to us, the sound recording of your voice, our staff’s impression of you and the other personal data which you provide to use 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 creation of 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 ONGOING ASSESSMENT OF YOUR SUITABILITY AS A SPERM DONOR
The purpose of and the legal basis for processing your personal data
Personal data
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 (Cryos Face Matching).
The facial comparison is done 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 a part 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).
Your sensitive personal data
For every donation we will register the sperm volume, the sperm cell concentration and the number of moving sperm cells.
We will ask you if you have been ill or if there has been any changes in your travel or risk behaviour since your last donation. In addition, we will take out blood samples and ask you to hand in urine- and in some cases sperm samples on a regularly basis, which we will test for different infectious and hereditary diseases.
The purpose is to ensure, on an ongoing basis, that you are suitable to be a donor. The legal basis is compliance with our legal obligation to make an ongoing 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).
Previously collected sensitive data
When you have been approved as a donor, we will continue to store sensitive data which 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 donor conceived person 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), (h), (i) and (f) 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 suitability assessment, including to determine your suitability as a donor either in general or in relation to a specific, potential recipient of your sperm:
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 with your sperm
c) If in connection with a genetic analysis in a child conceived with your sperm, 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 sperm will be an attractive match with the client’s own genetic profile (genetic matching)
e) If a potential client is aware that she herself is a carrier of a hereditary disease which makes it relevant by means of egg sorting to examine whether the use of your sperm can take place without transfer of the client’s hereditary 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 7 the Danish Executive Order on Human Tissue and Cells and Chapter 6 of the Danish Tissue Act cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) and (f) 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 DISTRIBUTION TO THE RECIPIENT
Your personal data
Each sperm donation is stored and registered together with information about your name, date of birth and date, location and time of donation. This data is collected in order to ensure traceability and identification and to administrate you as a donor.
The legal basis is compliance with our legal obligation to ensure a unique donor identification and traceability of the donated sperm (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
When you donate sperm, the purpose is to process and distribute the sperm to be used for fertility treatment and to conceive donor children. We also use your sperm for scientific research if you have provided us with a separate consent in this regard.
The legal basis for extracting your sperm for fertility treatment is your explicit consent (Section 21 of the Danish Executive Order on Human Tissue and Cells and Section 15 of the Danish Health Act). The legal basis for using your sperm for scientific research is your explicit consent (Article 9(2)(a) and Article 6(1)(a) of the General Data Protection Regulation).
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, cf.).
In case of a serious adverse reaction or an adverse event, e.g. if any hereditary diseases are suspected or diagnosed in you or a child conceived by using sperm 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 reaction/adverse event (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 sperm 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 address latest 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 created by using your sperm.
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 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 DONOR CANDIDATES:
If you do not become a donor
Information collected about you during the application 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. The initial semen sample is destroyed as soon as we have measured the sperm motility, which is no later than 2-3 days after extraction.
FOR DONORS:
If you are approved as a donor
We will store the information we have collected about you, including health information, information about your sexuality and information about your race and ethnic origin, for at least thirty (30) years from the most recent distribution of your sperm 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 sperm is distributed and used 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 distribution of your sperm. 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- urine and sperm 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.
Sperm will be stored as long as we consider it possible to use it for fertility treatment or for research purposes, if you have also consented thereto.
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, among other things, that you cannot, for example, 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 sperm from donation to distribution to 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 DONOR CANDIDATES:
Information that we process to assess your suitability as a sperm donor
Other companies in the Cryos Group will help us collect and analyse your initial sperm sample and any other information we collect about you in connection with the application procedure in order to help assessing 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- sperm- and urine samples. When requesting the tests, we share your date of birth or CPR number with our service partners. Your CPR number is only shared when requesting tests and receiving test results via the Danish public hospitals and in order to register and display the test results at your medical journal on Minsundhed.dk. The test centres can also store DNA material on behalf of Cryos. Cryos has entered into service agreements, including data processing agreements, with these service partners.
FOR 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 color and hair color
- Height and weight
- Race
- Ethnicity
- Blood type
- Our evaluation of your psychological profile
- Results of tests made for infectious and genetic diseases
- Number of available units in stock
- Sperm quality
- Type of sperm (ICI/IUI)
In connection with each order of sperm, this information about the donor will be sent to the buyer/recipient.
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 of you as an adult
- Information provided by completing our "extended profile questionnaire"
- A sound recording of your voice
- A handwritten message
- A staff impression of you as a person
- The result of an emotional intelligence test (EQ test)
- Your religion if any
If a recipient residing in a country outside the EU/EEA sees your donor profile on our website, orders or reserves sperm from you, the legal basis for our transfer of your personal data, including donor sperm from you, is the European Commission's standard agreement clauses for the transfer of personal data to unsecure third countries.
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 ordering, distribution and administration of your sperm.
Other processing and disclosure of your information in order to administrate you as a donor
Serious adverse events or serious adverse reactions
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 in other countries than Denmark that may have purchased or received your sperm.
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 customer wants to get her facial features compared to a donor's. Your photo will not be shared with the customer, 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 sperm to the fertility clinics we will 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 sperm from you.
If you have chosen to be an Early ID Release or ID Release Donor, Cryos will disclose your name, date of birth and your latest stated address to persons of at least 18 years of age and who can render probable, with a significant level of certainty, that they have been conceived with sperm 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 sperm.
The legal basis for disclosing the information specified above is our legitimate interest in distributing donor sperm to countries where the legislation so requires (Article 6(1)(f) of the General Data Protection Regulation) and the necessity of ensuring high standards of quality and safety around the product, which we distribute (Article 9(2)(i) of the General Data Protection Regulation).
Further disclosure
If we distribute your sperm 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 sperm and personal data for the purpose of medically assisted reproductive treatment.
To the extent where sperm from you has been distributed 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 the European Commission’s standard agreement clauses for the transfer of personal data to unsecure third countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
Based on a specific request from our clients we may disclose information about the number of units of sperm, we hold from a specific donor, and whether a donor is still active or if it is expected that additional units of sperm will be 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 about a donor's year of birth in case of an Early ID Release or ID Release Donor. In case of a Non-ID Release Donor, we will not disclose such information.
In some countries it is a legal requirement that the donor is alive at the time when the sperm is delivered by Cryos or used for treatment. When we supply donor sperm to these countries, we will check the civil registration number register in order to determine whether the said donor is alive before orders are shipped and in connection with treatment.
The legal basis for the collecting and disclosing the information specified above is our legitimate interest in distributing donor sperm 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’ stocks of your donated sperm 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, 5th floor
DK-8000 Aarhus C
Phone +45 8676 0699
Email: [email protected]
We will as soon as possible determine 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 28.05.2026