Privacy Policy

This notice is current from 03/09/2025. From time to time we may make changes to our policy, processes and systems in relation to how we handle your personal data. We will update this notice to reflect any changes. Updates are available on our website and in the clinic.

Thérapie Fertility is a trading name for Thérapie Fertility Limited (Company Registration Number: 507410), the data controller for the personal data we process for private or corporate-sponsored patients, unless otherwise stated.

Thérapie Fertility is the Data Processor for publicly funded HSE (Health Service Executive) care, where the HSE is the Data Controller.

Thérapie Fertility has a number of clinics. Our primary clinic is located in Dublin and there are several satellite clinics located in Ireland and in the United Kingdom. The primary clinic and the satellite clinics located in the Republic of Ireland are directly managed by Thérapie Fertility Ltd.

All data collected (from Republic of Ireland or the United Kingdom) is stored in the same location within the European Union and is processed as per this Privacy Policy. Only trained, authorised staff can access patient data.

There are many ways you can contact us, including by phone, email, post and Patient Portal.

Thérapie Fertility — First Floor, The Holbourne Building, Block 60, The Park, Carrickmines, Dublin 18, Ireland.

Contact number: +353 1 223 8933

Email: info@therapiefertility.com

Company registered address: Thérapie Fertility Limited, 60A South William Street, Dublin 2, Ireland.

Our Data Protection Officer is Cyrille Kuster. You can contact him at dpo@therapiefertility.com or via our postal address. Please address the envelope to 'Data Protection Officer'.

Personal data refers to information relating to an identified or identifiable person. It does not include data that has been anonymised and cannot be traced to an identified or identifiable person.

We currently collect and/or process the following personal data:

• Identifying and demographic information: full name, date of birth, gender, address, PPS number, DPS number, HSE UAN number if applicable, insurance information, phone number(s) and email address.

• Medical and health information (special categories): physical and mental health, test results, disabilities, family or individual health history, medical information relevant to your treatment at the clinic, blood type, ultrasound pictures, drug prescriptions.

• Relationship and sexual information (special categories): sex life information, information regarding sexual orientation and relationship.

• Financial information: payment preference, bank account details, credit card information.

• Digital images: photograph used to perform visual confirmation of identification, CCTV footage, and also ultrasound or hysteroscopy images, images of your eggs, embryos or sperm.

• Communication: record of interaction between patients and clinic such as consultations, emails, phone calls and posts; phone-call recordings; voicemails; emails.

• Patient preferences and feedback: opinions and intentions disclosed during communication with clinic, satisfaction survey responses, complaints.

• Electronic device information: IP address and cookies information when visiting our website (see our Cookie Policy).

Most of the personal information we process is provided to us directly by you from the following sources:

• Website contact form

• Website visits through cookies (see our Cookie Policy for more details)

• Phone or email queries

• Information you sent us on the Patient Registration Form and Health Questionnaires

• Information communicated to and by you throughout your treatment

• Information collected from testing and scanning you have throughout your treatment

On some occasions we will also receive personal information indirectly from third parties such as:

• HSE Fertility Hub referral

• GP or other specialist referral

• Other medical or corporate referral

• Test results performed by a third-party healthcare provider or laboratory

The table below sets out the purposes for which we process your personal data and the legal basis we rely on for each.

As part of your treatment with Thérapie Fertility, we will need to collect and process information concerning your health and concerning your sex life or sexual orientation. On some occasions, if required for treatment, we may also need to process information regarding your ethnicity and genetic data.

This information is considered Special Categories Personal Data under GDPR. As such we will only process your Special Categories Personal Data after you have given explicit consent to the processing of those personal data for the purpose of your treatment with us.

Your information is securely stored within our Patient Electronic Database System which also includes the integration of our Patient Portal.

The number of paper records processed at Thérapie Fertility is very limited and stored internally in our secured facilities.

All personal data is kept as per Thérapie Fertility's Retention Policy. Information related to treatments where gametes and embryos were processed will be kept for 30 years after clinical use as per EU Directive 2004/23/EC and Irish Regulation S.I. No. 158/2006.

Phone-call recordings are securely stored with one of Thérapie Fertility's third-party providers and will be deleted after 3 months. Only authorised staff can access phone recordings, and only for quality and training purposes.

CCTV recordings in our Carrickmines Clinic are securely stored in an authorised-staff-only area managed directly by Thérapie Fertility and are not accessible online. CCTV recordings are deleted after 28 days.

In order to provide you with the best quality of care, and to comply with our legal obligations, some of your personal data will be shared on a need-to-know basis with the following third parties:

• Testing laboratories or other healthcare providers that require your personal data as part of the provision of medical treatment;

• Service providers and other third-party advisors (e.g. legal advisor, insurance) that have access to your personal data as a necessary and controlled part of the provision of service;

• Other companies of the Thérapie Medical Group, including Thérapie Fertility UK Ltd (Belfast) and Thérapie Medical (UK) Ltd (Angel, London), as well as IT, marketing and financial services shared across the Group;

• Regulatory and accreditation bodies including the HPRA, DPC, JCI and CQC;

• HSE Fertility Hubs: if you have been referred by the HSE for treatment, we will share treatment details and outcomes with them.

If you wish to obtain more information on third parties with whom your data may be shared, please contact our Data Protection Officer at dpo@therapiefertility.com.

We will not transfer your personal data outside the European Union / United Kingdom except for the temporary storage of your electronic consent forms, which will be stored by an approved third-party provider on a server located in the US under the EU–U.S. Data Privacy Framework (including its UK Extension).

Authorised fertility nursing staff based in the United Kingdom at Thérapie Fertility UK Ltd and Thérapie Medical UK Ltd have access to, and will process, Thérapie Fertility's patient data in line with this Privacy Policy.

Under data protection law, you have rights including:

• Right of access — ask us for copies of your personal information.

• Right to rectification — ask us to rectify personal information you think is inaccurate, or complete information you think is incomplete.

• Right to erasure — ask us to erase your personal information in certain circumstances. This right is not absolute — some data must be kept under other legal obligations such as the EU Tissue and Cell Directive 2004/23/EC.

• Right to restriction of processing — ask us to restrict the processing of your personal information in certain circumstances.

• Right to object to processing — object to the processing of your personal information in certain circumstances.

• Right to data portability — ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at dpo@therapiefertility.com if you wish to make a request.

If you have any concerns about our use of your personal data, please contact us at dpo@therapiefertility.com.

If you are unhappy with how we have used your data, you can also complain to the Irish Data Protection Commission (DPC):

• Helpdesk (Mon–Fri): +353 (0)1 765 01 00 (9.30am–1pm) or +353 1800 437 737 (2pm–5pm)

• Online contact form: forms.dataprotection.ie/contact

• Website: dataprotection.ie