TFP Fertility Privacy Policy

At TFP, we value your trust and confidence. This privacy policy explains what types of personal information will be gathered when you visit TFP's website, how we keep it secure, and how this information will be used. We are committed to being transparent and ensuring the protection of your privacy.

General Information

This Privacy Policy describes how TFP Fertility Group Ltd and the relevant TFP company or clinic providing your services collect and process personal information when you visit our website, use our digital applications, enquire about or receive treatment, or interact with us through clinics, telephone services, live chat, email or social media. The TFP company or clinic responsible for deciding how and why your information is processed is the controller for that processing. Where more than one TFP entity is involved, we will explain their respective roles where required. This policy applies to the UK website at www.tfp-fertility.com and to the patient services described in this policy.

What data do we collect?

You directly provide most of the information we collect. We collect and process data you provide via three methods:

Information that you provide us:

• Contact Information: Your name, email address, mailing address, and phone number when you register for TFP Services, subscribe to TFP marketing, communicate with us, or make an enquiry.

• Patient Registration Information: Information provided in connection with your TFP "Patient Profile," including contact information, username, medical history, weight, height, age, gender, and other relevant details you consent to provide.

• Communications Information: Details of your interactions with our clinical or support teams, including phone calls, emails, live chats, video calls and social media interactions. Depending on the telephone system used, this may include call recordings, transcripts, call summaries and AI-assisted analysis. Further information about when these functions apply and how this information is used is provided under Phone Recording.

• Survey and Review Information: Information you provide in surveys or testimonials about TFP goods and/or Services.

• Payment details including card details or bank account details.

• Other User Information: Any other data you provide related to your use of TFP Treatment or Services, such as event bookings, appointment scheduling, and personal experience feedback.

Information we collect automatically:

• Information generated through your use of the Services, events attended, appointments booked, classes attended, and phone enquiries made to TFP.

• Patient Feedback from Patient Experience surveys received.

Website usage and analytics:

When someone visits TFP Fertility UK Homepage | TFP (tfp-fertility.com), we use Google Analytics: Standard internet tracking information collected anonymously to understand website usage patterns. We do not attempt to identify individual visitors through this data. If you visit our website, we collect the data below which are technically necessary for us to show you our website and ensure its stability and security:

• IP address

• Date and time of your inquiry

• Time zone difference to Greenwich Mean Time (GMT)

• Content of the request (page visited)

• Access status / HTTP status code

• Amount of data transmitted

• Referring website (the page from which the request originated)

• Browser type and version

• Operating system and interface

• Language and version of the browser software

GA4 is only activated after you give consent for analytics cookies via our Cookie Preference Centre (OneTrust). If you do not provide consent, GA4 is not loaded and no analytics data is collected.

GA4 processes information such as page views, navigation paths, device type and general location (city-level).

IP addresses are processed by Google to provide the service, and we have enabled IP anonymisation and restricted data-sharing settings within our configuration.

We use Google Consent Mode v2, which ensures that, when consent is withheld, only limited, non-identifiable measurement data is sent to Google.

You can change or withdraw your analytics-cookie consent at any time by selecting “Cookie Settings” at the bottom of any page.

For more information about how Google processes data, please refer to the Google Privacy Policy.

CCTV Recording

Our facility is equipped with closed-circuit television (CCTV) cameras for the safety and security of our patients, staff, and property. These cameras are strategically placed in common areas and are not used in private or sensitive locations.

We use CCTV recordings to:

• Deter and detect unauthorised access or security incidents.

• Investigate any incidents that may occur on our premises.

• Ensure a safe environment for everyone visiting our facility.

• How We Handle CCTV Data

CCTV footage is securely stored and accessible only to authorised personnel.

• Retention Period: Recordings are retained for a limited time unless they are required for an investigation or legal purpose.

• Access: Footage is accessed only for legitimate security purposes and is not shared with third parties except when required by law or to assist law enforcement.

Phone Recording

TFP uses different telephone systems across its clinics and services. This means that not all calls are recorded or processed in the same way. Calls handled through our Zoom telephone and contact centre system will be recorded and transcribed. This applies to both inbound and outbound calls. Where these functions apply, you will be informed. We use recordings, transcripts and related outputs for quality assurance, staff training, complaint or incident investigation, compliance monitoring and service improvement. Artificial intelligence may also be used to produce call summaries and analyse the words used in transcripts to indicate possible dissatisfaction or identify recurring questions. These outputs are indicators only: they are reviewed by authorised staff and are not used to make decisions about you solely by automated means. Calls to other TFP clinics or services may continue to use our existing telephone arrangements. These calls may not be recorded. Where they are recorded, this is generally for training and monitoring purposes. Call360 records and transcribes calls and uses AI to analyse the words used to inform marketing decisions. If a call is transferred to a clinic, recording may continue. We will provide an announcement or other notification where a call is being recorded or transcribed.

Where we rely on legitimate interests for call recording, transcription or AI-assisted analysis, you may object to this processing. We will consider your objection in accordance with data protection law. Where applicable, we can arrange an alternative communication route that does not use the AI-assisted transcription and analysis functions but will include call recording, so that you can continue to communicate with us. If your objection relates to direct marketing, we will stop using your information for that purpose.

Portal documents

Documents uploaded to portals are only held within patient portals for a maximum of 60 days. The documents can be reinstated on the portal after this time if requested.

Wi-Fi Splash Page

We may collect limited technical information generated when you use guest Wi-Fi services at our premises, such as Device type, Operating System, IP address, your device’s MAC address, Device capable Wi-Fi standards, and connection logs.

Information we collect from Third Parties 

• Third-Party Applications: Information collected through third-party applications like App Stores or Social Networking Sites, where you have made certain data public via your privacy settings.

• Third-Party Sources: Information received from other sources to supplement the data you provide, enhancing our ability to provide information about our business, products, and Services.

We also use Google Analytics 4 (GA4) to analyse website usage and improve our services.

Analytics and Third-Party Tools

We use the following analytics and related tools to improve user experience, understand how our website is used, and support the effective delivery of our services.

Where analytics, marketing, or optimisation tools rely on cookies or similar technologies, they operate only where you have provided consent via our cookie banner. Further information about our use of cookies and consent controls is available in our Cookie Policy.

1. Google Analytics: Collects pseudonymised website usage data using cookies to help us understand how visitors interact with our website, such as which pages are viewed and how long users spend on them. We do not attempt to identify individual visitors through this data. You may opt out by installing the Google Analytics Opt-Out Browser Add-on.

2. Plausible Analytics: A privacy-focused analytics tool used to measure website usage in an aggregated and anonymised way. Plausible Analytics does not use cookies, does not store personal data, and does not track users across websites or devices. It operates on the basis of our legitimate interests in understanding overall website performance and improving our digital services. Further information is available in the Plausible Privacy Policy

3. Microsoft Clarity and Microsoft Advertising: Capture pseudonymised behavioural data, including interaction metrics, heatmaps, and session insights, to help us understand how users engage with our website and to improve our products and services. These tools rely on cookies and similar technologies and operate only where consent has been provided. Further information is available in the Microsoft Privacy Policy.

4. VWO (Visual Website Optimizer, Wingify Software Pvt. Ltd.): Used for A/B testing and website optimisation. VWO collects pseudonymised or aggregated interaction data, such as click behaviour and scroll activity, to help improve website usability and performance. While Wingify Software Pvt. Ltd. is based in India, visitor data is processed in data centres located within the EEA. Where applicable, international data transfers are protected using appropriate safeguards in accordance with data protection law. Further information is available in the VWO Privacy Policy.

5. Meta Pixel (Facebook/Instagram): Used to measure advertising performance, understand conversion activity, and optimise campaigns across Meta platforms. This tool relies on cookies and similar technologies and operates only where consent has been provided. Further information is available in the Meta Privacy Policy.

6. LinkedIn Insight Tag: Used to measure the effectiveness of LinkedIn advertising campaigns and enable remarketing. This tool relies on cookies and similar technologies and operates only where consent has been provided. Further information is available in the LinkedIn Privacy Policy.

7. Call360 (Esale): Used to track telephone calls generated via dynamic phone numbers in order to understand marketing attribution and improve service performance. Dynamic numbers are displayed only where users have consented to targeting cookies via our cookie banner (OneTrust). This approach ensures compliance with the EU ePrivacy Directive and GDPR. Further information is available in the Call360 Privacy Policy. Calls are recorded and retained (for up to 30 days) within Call360 and transcribed by the application and that AI is used to analyse the words used to inform marketing decisions Call360 Privacy Policy.

8. Hotjar: Used to collect pseudonymised or aggregated usage data, including session insights and heatmaps, to help us understand how visitors interact with our website and to improve content and usability. Hotjar relies on cookies and similar technologies and operates only where consent has been provided. Further information is available in the Hotjar Privacy Policy.

9. Edudip (Webinar Registration Platform): Used to host webinars and manage event registrations. When you register for a webinar, you may be redirected to an Edudip-hosted registration page. Edudip collects personal data such as your name and email address on our behalf for the purpose of managing attendance and follow-up communications. Edudip acts as a processor in this context. Further information is available in the Edudip Privacy Policy.

10. Storyblok (Website Content Delivery): Used to manage and deliver the content displayed on our website, including page structure and form layouts. Storyblok does not process or store form submission data. When you submit a contact or enquiry form, your information is transmitted securely directly to TFP and is not retained by Storyblok. Further information is available in the Storyblok Privacy Policy.

How we use your personal data

User-provided information:

• Personal information you provide to TFP will only be used for the stated purposes, such as providing information about our treatments and seeking feedback from you.

• Personal information will not be sold to third parties or provided to direct marketing companies without your explicit permission.

• While contacting TFP for treatment we ask you for your active and free consent according to Art. 6 (1) (a) GDPR EU 2016/679, UK 2018 for taking part in our patient feedback surveys. Based on your content you will receive emails asking you about your experience during the different stages of your treatment. The process controller for sending the mails is your clinic, for the surveys we need: your first and last name, your email address and the questions and answers in the survey. Please note, the survey results are personal and could be – theoretically – associated to your patient file within the clinic. It is possible, that a staff member of the clinic contacts you afterwards the survey e.g., for discussing what you need for a complete treatment or how to improve negative aspects.

• We use third-party tools such as VWO to improve website functionality and user experience. VWO helps us conduct A/B testing, track user engagement, and analyse browsing patterns to enhance site usability. The data collected is pseudonymised or aggregated, does not directly identify individual users, and does not contain personally identifiable information (PII).

• Telephone and contact centre services: We use call recordings, transcripts and AI-assisted outputs to operate relevant telephone and contact centre services; maintain and improve service quality; train and support staff; investigate complaints, incidents and compliance concerns; identify recurring questions so that we can improve patient information; and support appropriate follow-up with people who have already contacted us. These activities apply only where the relevant telephone functions are enabled.

Automatic demographic and statistical information:

• Information collected through Google Analytics is used to evaluate the effectiveness of TFP's website and improve content relevance and marketing campaigns.

• Any disclosure of this information will be aggregated or pseudonymised and will not directly identify individual users.

How we store your data

We are dedicated to safeguarding your data:

• Regular review of information collection, storage, and processing practices to protect against unauthorised access.

• Restricted access to personal information to authorised TFP/Clinic employees, contractors, and agents, subject to strict confidentiality obligations.

• Commercially reasonable administrative, technical, and physical safeguards to protect against unauthorised access, disclosure, or access of personal information.

• Personal information is stored on secure servers hosted by a third-party contractor, Vercel, in the United States, complying with the UK Extension to the EU-US Data Privacy Framework (DPF), also known as the UK-US Data Bridge

• We use secure systems and carefully selected third-party providers to store and process personal information. Access is restricted according to role and business need, and security measures include encryption, multi-factor authentication, logging and monitoring. The location of processing depends on the service used. Further information about processing outside the UK, including the arrangements for our Zoom telephone and contact centre services, is provided in the International Data Transfers section.

• For surveys, we use AskNicely, and all data transfers between TFP companies are governed by Data Protection Agreements (DPA). Patient Data will primarily be stored at your registered clinic; however, we sometimes perform scans using a partner organization, Ultrasound Direct. If you receive a scan as part of your treatment, they may store and process your data in accordance with their privacy policy

Data retention period

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and in accordance with our Records Management and Retention Schedule, applicable legislation and regulatory requirements

Telephone recordings, transcripts and AI-assisted outputs

Telephone recordings, transcripts, interaction records and AI-assisted outputs created through the Zoom telephone and contact centre system are retained in accordance with our Records Management and Retention Schedule and applicable healthcare, legal and regulatory requirements.

Records that form part of, or provide evidence relevant to, a patient’s clinical record must be retained for the applicable clinical-record period and cannot be deleted earlier simply because the original recording would otherwise have reached the end of its standard retention period.

Under HFEA requirements, specified patient and donor records relating to licensed treatment must generally be retained for at least 30 years from the date on which gametes or embryos were used in treatment or, if they were not used, from the date on which they were removed from storage.

In certain circumstances, HFEA requirements extend the minimum period to 50 years from the date on which information about the treatment was first recorded, including where a patient underwent treatment other than basic partner treatment and the clinic cannot confirm whether a child was born as a result.

The applicable period therefore depends on the nature and circumstances of the treatment record, rather than solely on whether donor gametes or embryos were involved.

A relevant telephone recording, transcript, call summary or interaction record may need to be retained for the same period where it contains clinical information, records advice or decisions about treatment, documents consent or instructions, or is otherwise necessary to understand or evidence the care provided.

Recordings made through other telephone arrangements are normally retained for 30 days where they do not form part of the clinical record, unless they need to be preserved for a complaint, investigation, legal claim, safeguarding matter or another applicable requirement.

Information is securely deleted when the relevant retention period expires.

Other healthcare and legal requirements

Other healthcare and legal requirements may also affect how long records are retained. These include requirements and guidance concerning access to records after death, records management, limitation periods, regulated healthcare services and licensed fertility treatment.

The applicable retention period is set out in our Records Management and Retention Schedule and depends on the nature of the record and the legal or regulatory purpose for retaining it.

Marketing

We may send you information about our products and services, and those of our affiliates or partners, with your consent. You can unsubscribe from marketing communications at any time.

Cookie technology

Our website uses cookies and similar tracking technologies to improve your browsing experience. We use a Cookie Consent Centre (OneTrust) to manage your cookie preferences in accordance with the EU ePrivacy Directive and the General Data Protection Regulation (GDPR).

Strictly necessary cookies are placed automatically to ensure the website functions properly.
Non-essential cookies, such as analytics, advertising and social media cookies, are only activated after you provide explicit, informed consent through the Cookie Consent Centre.

You can review, update or withdraw your consent for non-essential cookies at any time by selecting “Cookie Settings” at the bottom of any page.

If you wish, you may also delete cookies already stored on your device using your browser settings. However, this does not change your consent preferences; cookie consent is managed exclusively through the Cookie Consent Centre.

For more details about the cookies we use and how we manage consent, please see our Cookie Policy.

Who we share your personal information with?

We may disclose your personal information to the following categories of recipients:

• TFP Group companies, subsidiaries and clinics: We may share your personal information within the TFP Group where necessary to provide and coordinate your care, manage our services, maintain patient records, provide administrative support and meet our legal and regulatory obligations. Appropriate data protection arrangements are in place between TFP Group entities.

• Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts, or other Third Parties: When required to comply with the law, establish legal rights, protect vital interests, or detect/prevent security or fraud issues.

• Human Fertilisation and Embryology Authority: HFEA-licensed clinics are legally required to provide specified patient, treatment and outcome information to the HFEA for inclusion in its Register of Treatments. Further information is available in the HFEA privacy policy: Privacy policy | HFEA

• Communications Service Providers: We use third-party providers, including Zoom and implementation or support providers acting on our behalf, to deliver relevant telephone and contact centre services. Depending on how you contact us and which system handles the call, these providers may process contact details, call and message metadata, recordings, transcripts, call summaries and other interaction information, which may include health information disclosed during a conversation. Contracts and data protection safeguards are in place to govern this processing.

• Your partner in joint treatment: Where you and a partner are receiving treatment together or creating embryos together, some information about the treatment may need to be discussed jointly. We will protect each person’s confidentiality wherever possible and will share information only where it is necessary to provide safe and effective care, explain treatment recommendations, or meet legal and regulatory requirements.

• Verified caller identification: To help you identify genuine calls from us, we may use a service that displays TFP Fertility (or the relevant TFP clinic) as the verified caller name on compatible mobile devices and networks. Please be aware that anyone who can see your phone screen when we call may also be able to see that the call is from TFP Fertility. If you share your device or would prefer us to contact you in another way, please let us know. Any third-party provider used to deliver this service processes only the minimum information required and is subject to appropriate contractual, security and data protection safeguards.

Privacy policy for other websites

Our privacy policy applies to our website. If you follow a link to another website, please review their privacy policy.

International data transfers

Your personal data may be transferred to and processed in countries outside your country of residence. For our Zoom telephone and contact centre services, call content such as recordings, transcripts and summaries is hosted in the United Kingdom, with disaster-recovery failover in the Netherlands. Limited diagnostic, telemetry and service-generated metadata may be processed in the United States for service operation, security, support and troubleshooting. Other third-party providers, including Google, Meta, Microsoft, Hotjar, LinkedIn, Call360, Vercel and VWO, may also operate outside the UK. Where personal data is transferred outside the UK, TFP uses appropriate safeguards in accordance with UK data protection legislation. Depending on the transfer, these may include UK adequacy regulations, including the UK Extension to the EU-U.S. Data Privacy Framework where applicable, the UK International Data Transfer Agreement or Addendum, Standard Contractual Clauses, and supplementary technical and organisational measures. We monitor these arrangements and review them if a provider’s certification, the law or the categories of data transferred change.

Legal basis for processing

TFP Fertility Group Ltd collect information from individuals for various purposes related to providing fertility-related services, ensuring effective care, complying with legal requirements, and safeguarding the vital interests of individuals. The legal basis for processing data is shown below:

• Health and treatment information: To provide fertility care, we need to use information about your health, treatment and genetics. We may also need information about your sex life or sexual orientation where it is relevant to your care. Data protection law gives this information extra protection. We use it only where the law allows us to do so, for example to provide and manage your care, meet our legal and regulatory duties, protect important public interests or where you have given explicit consent for a particular purpose.

• Contractual Performance: TFP collect and processes personal information based on the necessity of fulfilling the contractual obligations between TFP and the individuals supply data. This includes data required for scheduling appointments, providing fertility treatments, managing patient records, and processing payments for the services rendered.

• Legitimate Interests: TFP processes personal data where this is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. These interests include improving the quality and consistency of our services, training and supporting staff, investigating complaints and incidents, maintaining security, improving patient information and, where the relevant functions are enabled, using call recordings, transcripts and AI-assisted analytical outputs for quality assurance and service improvement. We assess and balance these interests against the nature of the information involved, including health information. You may object to processing based on legitimate interests, as explained in the Your Rights section. In certain circumstances prescribed by law, including recognised legitimate interests under the Data (Use and Access) Act 2025, we may rely upon these lawful grounds where applicable.

• Consent: TFP seek explicit consent from patients or individuals for specific data processing activities. This could include obtaining consent for conducting fertility-related research studies, sharing medical information with other healthcare providers, or using personal data for marketing purposes. Consent should be freely given, informed, and easily revocable by the individual at any time.

• Legal Obligations: TFP is subject to various legal requirements and regulatory obligations. Data processing may be necessary to comply with these legal obligations, which could include maintaining accurate medical records, reporting certain medical conditions to health authorities, and adhering to data protection and healthcare laws.

• Protecting Vital Interests: In certain critical situations where an individual's life or health is at risk, TFP may process personal data based on the vital interests of the individual. For example, during emergency medical situations, TFP may access relevant medical information to provide timely and appropriate medical care.

• Automated decision making: TFP does not make decisions about individuals which produce legal or similarly significant effects solely by automated means. Where technology is used to support clinical or administrative decision-making, meaningful human oversight is always retained.

It's essential for TFP to be transparent and inform individuals about the specific purposes for which their data is being collected and processed, as well as the legal basis for each processing activity. Patients should also be made aware of their rights regarding their personal data, including the right to access, rectify, erase, and object to the processing of their data. By adhering to data protection regulations and ensuring clear communication with patients, fertility companies can build trust and maintain the confidentiality and security of personal information.

Changes to our privacy policy

We regularly review our compliance with this privacy policy. Any changes will be posted on our website and, where appropriate, notified to you by email.

Last updated on 09 November 2026.

Your rights

Under UK data protection law, you may have the right to access your personal data, have inaccurate information corrected, request erasure, restrict processing, object to processing and receive certain information in a portable format. You may also withdraw consent where consent is the basis for processing and complain to the Information Commissioner’s Office or another relevant supervisory authority. These rights are not absolute and may be limited where we must retain or use information to comply with healthcare, legal or regulatory obligations. Where we rely on legitimate interests, including for certain call recording, transcription and AI-assisted analysis, you may object to that processing. We will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims. If the processing is for direct marketing, we will stop using your information for that purpose when you object. You may also request access to relevant call recordings, transcripts and associated personal data, subject to applicable exemptions and the rights of other people.

Retention of Health Records

Under applicable laws and regulations, we are required to retain health records for a specified period, even if you request their deletion. Health records are critical for ensuring continuity of care, meeting legal obligations, and maintaining an accurate medical history.

Why Health Records Cannot Be Deleted on Request

• Legal Compliance: Healthcare providers are legally mandated to retain medical records for a minimum period to comply with laws and regulations.

• Continuity of Care: Your health records provide a comprehensive history that ensures safe and effective treatment in the future.

• Public Interest: Retaining health records is necessary to fulfil public health responsibilities, facilitate medical research (where applicable), and address potential legal claims or inquiries.

While we cannot delete your health records on request, we are committed to ensuring your data is handled securely and used only for appropriate purposes.

How to contact us

If you have any questions or concerns about this Privacy Policy or how we process your personal data, please contact us using the details below:

United Kingdom - Contact Section (Data Protection Inquiries)

Data Protection Officer: Michelle Wild

Post: TFP Fertility Ltd, Institute of Reproductive Sciences, Oxford Business Park North, Alec Issigonis Way, Oxford, OX4 2HW, United Kingdom
Phone: 0808 164 5341
Email: dpo@tfp-fertility.com

European Union – GDPR Article 27 Representative

In accordance with Article 27 of the EU and UK GDPR, we have appointed an authorised representative within the European Union to act on our behalf regarding GDPR compliance for individuals located in the EU/EEA.

Poland - Contact Section (Data Protection Inquiries)

Data Protection Officer: Dr Anna Janicka

Address: ul. Wojska Polskiego 103, 70-483 Szczecin
Phone: +48 91 486 43 45 / +48 691 676 305
Email: anna.janicka@tfp-fertility.com

Vitrolive Limited liability company with registered office in Szczecin
Post: TFP Fertility Vitrolive, Vitrolive Sp. z o.o., ul. Wojska Polskiego 103, 70-483 Szczecin
KRS: 0000252423 | REGON: 320166514 | NIP: PL8512959483
Phone: +48 91 48 64 345
Email: vitrolive@tfp-fertility.com

Macierzyństwo Medical Center Limited liability company Limited partnership with its registered office in Kraków
Post: TFP Fertility Macierzyństwo, Centrum Medyczne Macierzyństwo Sp. z o.o. Sp. k., ul. Białoprądnicka 7A, 31-221 Kraków
KRS: 0000343047 | REGON: 356524003 | NIP: PL6782853606
Phone: +48 124 158 800
Email: motherhood@tfp-fertility.com