Privacy policy

Privacy Policy for OVOM Care GmbH

Ovom Care GmbH (Ovom Care, we, us and our) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

Important information and who we are

We are the controller of the personal data set out in this privacy policy and we are responsible for how this personal data is held and used. If you have any questions about this privacy notice or our data protection practices, please contact us using the following details:

Email: operations@ovomcare.com
Post: Max-Urich-Straße 3, 13355 Berlin, Germany
Telephone: +49 176 43289981

In addition, we have appointed an external data protection officer (DPO) for our company:

​​E-Mail: datenschutzbeauftragter@ovomcare.com
Herting Oberbeck Datenschutz GmbH
Hallerstr. 76, 20146 Hamburg
https://www.datenschutzkanzlei.de

If you wish to contact our data protection officer, please mention what your request relates to and refrain if possible from enclosing sensitive information such as a copy of an ID card with your request.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Our website is not intended for children, and we do not knowingly collect data relating to children. We keep our privacy policy under regular review. This version was last updated on 10.12.2024.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 09.12.2024. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us or our partner clinics.

Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App or website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

To the extent that any Special Categories of Personal Data are collected via our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health, medical records and treatment plans, and genetic and biometric data) it will be for the purpose of providing our services to you.

The lawful basis for processing data is for the performance of a contract with you, and the condition for processing is Article 9(2)(a): explicit consent. We do not collect any information about criminal convictions and offences.

When using the website, we collect information that you provide directly. Additionally, certain details about your use of the website are automatically collected during your visit.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer including to create your user account in the App or the website (a)Identity
(b)Contact
(c)Financial
(d)Profile
(e)Special categories of personal data
(a)Performance of a contract with you
(b)Article 9 basis for processing special categories of personal data: Article 9(2)(a): explicit consent.
To process and deliver our services including:
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us or our partner clinics
(a)Identity
(b)Contact
(c)Financial
(d)Transaction
(e)Marketing and Communications
(a)Performance of a contract with you
(b)Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Replying to requests for information.
Notifying you about changes to our terms or privacy policy.
Asking you to leave a review or take a survey.
(a)Identity
(b)Contact
(c)Profile
(d)Marketing and Communications
(e)Special categories of personal data
(a)Performance of a contract with you
(b)Necessary to comply with a legal obligation
(c)Necessary for our legitimate interests (to keep our records updated and to study how potential customers use our goods or services)
(d)Article 9 basis for processing special categories of personal data: Article 9(2)(a): explicit consent.
To send you notifications on the App containing information about our services and information about your account (where you have given us permission to do so by enabling this feature on the App) (a)Identity
(b)Contact
(c)Profile
(d)Marketing Communications
(e)Special categories of personal data
(a)Necessary for the performance of the contract with you for the operation of your account
(b)Necessary for our legitimate interests to ensure that you receive an appropriate level of service
(c)Article 9 basis for processing special categories of personal data:(d)Article 9(2)(a): explicit consent.
To process our services including for you to be able to update the App with details relating to the fertility treatment provided by our partner clinics. (a)Identity
(b)Contact
(c)Profile
(d)Special categories of personal data
(a)Performance of a contract with you
(b)Article 9 basis for processing special categories of personal data: Article 9(2)(a): explicit consent.
To administer and protect our business, the App, and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) (a)Identity
(b)Contact
(c)Technical
(a) Explicit consent
(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(c)Necessary to comply with a legal obligation
To deliver relevant App and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a)Identity
(b)Contact
(c)Profile
(d)Usage
(e)Marketing and Communications
(f)Technical
(a)Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business, and to inform our marketing strategy)
To use data analytics to improve our App, website, services, marketing, customer relationships, and experiences (a)Identity
(b)Technical
(c)Usage
(d)Special Categories of personal data
(a)Necessary for our legitimate interests (to provide our services, to keep our App and website updated and relevant, to develop our business and to inform our marketing strategy)
(b)Article 9 basis for processing special categories of personal data: Article 9(2)(a): explicit consent.
To make suggestions and recommendations to you about services that may be of interest to you (a)Identity
(b)Contact
(c)Technical
(d)Usage
(e)Profile
(f)Marketing and Communications
(a)Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which goods or services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions.

Cookies

We use cookies and similar technologies on our website. Cookies are small data files stored by your browser when you visit a website, allowing your browser to be identified and recognized by web servers. You have full control over the use of cookies through your browser settings, where you can delete cookies at any time or restrict their use either entirely or in specific cases.Some cookies are technically necessary for the website's operation and can be used without user consent. Additionally, we may use cookies to provide special features, analyze site usage, or for marketing purposes. This includes third-party cookies, which are only used with your consent, in compliance with § 25 (1) TTDSG and, if applicable, Art. 6 (1)(a) GDPR.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out belowOur partner clinics including A.R.G.C. LIMITED, trading as ARGC who will be acting as a data controller and who have data access pursuant to a contract entered into between you and the partner clinic for the provision of fertility services. For information on how ARGC will process your personal data, please refer to ARGC's privacy policy which is available here: https://argc.co.uk/privacy-policy-2/.

Service providers acting as processors who provide IT and system administration services, such as:

Use of Google AdSense
This website uses Google AdSense, an advertising service provided by Google Inc. ("Google"). Google AdSense uses "cookies" (text files stored on your device) to analyze your use of the website. It also employs "web beacons" (small invisible images) to collect information.

Use of Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics employs "cookies," which are text files stored on your device, to enable analysis of how users interact with the website.

Calendly LLC (booking of consultations)
For simple, fast and uncomplicated booking of consultations, we use the tool Calendly by the Calendly LLC based in the USA.

HubSpot (Customer Relationship Management)
We use HubSpot, a Customer Relationship Management (CRM) tool provided by HubSpot, Inc., to streamline and enhance the efficiency of services provided to our users.

Typeform (Feedback, Surveys)
We use Typeform SL ("Typeform") to gather feedback and conduct surveys.

Slack Technologies (Communication)
For communication purposes, we utilise Slack Technologies ("Slack").Providers supporting and enhancing the delivery of our services, including, but not limited to:

AI-based Analysis: Providers assisting with data-driven insights to improve clinical outcomes and operational efficiency.

Laboratory Services: External blood testing and genetic testing labs performing diagnostic analyses to support treatment plans.

Other Specialized Services: Providers offering additional services necessary to deliver our offerings efficiently and securely.Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom and the EU who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the UK or the EU, we ensure it is afforded a similar degree of protection by implementing at least one of the following safeguards:

Adequacy Decision: We will only transfer your personal data to countries deemed to provide an adequate level of protection for personal data by either the UK Government or the European Commission.

Standard Contractual Clauses: Where we use certain service providers, we may rely on contracts incorporating Standard Contractual Clauses approved for use in both the UK and the EU, ensuring your personal data is protected at the same level as within these regions.If you would like further information on the specific mechanisms we use when transferring your personal data outside the UK or EU, please do not hesitate to contact us.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under data protection laws, you have several rights regarding your personal data, including the right to:

Access your personal data (data subject access request) to check its lawfulness.

Correct any incomplete or inaccurate data we hold about you.

Erase your personal data in certain circumstances, such as when there is no valid reason for its continued processing or when you successfully object to its use. However, legal reasons may prevent us from erasing it.

Object to processing based on legitimate interest or for direct marketing, especially if it impacts your rights and freedoms. In some cases, we may demonstrate overriding legitimate grounds.

Restrict the processing of your personal data in certain scenarios, such as verifying its accuracy or holding it for legal claims.

Transfer your data to you or a third party in a structured, machine-readable format if it was provided with consent or as part of a contract.

Withdraw your consent to process your personal data at any time, without affecting the lawfulness of previous processing. However, certain services may not be available if consent is withdrawn.

File a complaint with the Information Commissioner's Office (ICO), the UK regulator (www.ico.org.uk), or the German data protection authority (BfDI) (www.bfdi.bund.de). We encourage you to contact us first to resolve any issues before approaching these authorities.If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.