Privacy Policy
last updated: May 2018
- Introduction
British Surrogacy Centre provides password protected, secure access to view a database of egg donors and surrogates. We also take online registrations where you submit many personal details to us via web forms.
Any information stored on British Surrogacy Centre’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. British Surrogacy Centre implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
- Collection and use
2.1 .General
The following sections cover the specifics for ‘Website Visitors’ and ‘Respondents’ (Users who submitted data via a web form)
2.2 Website Visitors
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
British Surrogacy Centre may collect, record and analyse information of Visitors to its website. We may record your IP address and use cookies. British Surrogacy Centre may add information collected by way of pageview activity. Furthermore, British Surrogacy Centre may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you contact us via a web form or sign up to become an egg donor or surrogate.
Such Personal Data may comprise your IP address, first and last name, your postal and email address and your telephone number.
British Surrogacy Centre gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.
2.2.1 Purpose of processing personal data
British Surrogacy Centre uses the collected data to communicate with Visitors and to improve its website by analysing how Visitors navigate its website.
It will also use your details on our internal database of egg donors and surrogates if you have signed up to become one. This information will be available for our registered intended parents to view as per our terms and conditions of your registration.
2.2.2 Sharing personal data
British Surrogacy Centre will not share your personal data with any third-party organisations, some visitor data is used to analyse the Visitor behaviour on our website.
2.2.3 Cookies
Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.
2.2.4 Links to other sites
Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. British Surrogacy Centre is not responsible for the content or privacy policy of these other sites.
2.3 Respondents
Respondents should be aware that by completing a website contact form they are disclosing information that will make them personally identifiable to British Surrogacy Centre employees. The security and privacy protection implemented on British Surrogacy Centre’s internal platform will not expose your data to third-parties outside of our own organisation.
2.3.1. Inquires
If you wish to inquire about your Personal Data that we may have on file for you, we recommend that you visit our contact us page and speak to our team. After confirming your identity we will supply you with all the details we have on file.
2.4 Users
2.4.1. General
In order to provide services to its Users, British Surrogacy Centre collects certain types of data from them. Furthermore, British Surrogacy Centre staff collect information from Respondents when they register to become egg donors or surrogates. This section will describe how these two types of data are collected and used by British Surrogacy Centre as well as geographical differences that effect this policy. Data entered or transferred into British Surrogacy Centre by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by British Surrogacy Centre without express consent from the User.
2.4.2 Collection of User data
During a User’s registration and later on British Surrogacy Centre’s platform, they provide information such as name, email, address, telephone, and other relevant data. This information is used by British Surrogacy Centre to identify the User and provide them with support, services, mailings and to meet contractual obligations.
British Surrogacy Centre Users can at any time access and edit, update or delete their contact details by contacting a member of our team.
British Surrogacy Centre Users may create free accounts to allow access to view a database of registered egg donors or surrogates. Users will be able to view images and personal data or registered egg donors and surrogates, but never personal names or direct contact details.
British Surrogacy Centre will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
2.4.3 Collection of Respondent data
Respondent data includes data from individuals uploaded, transferred or manually entered by a British Surrogacy Centre User into their account for the purpose of providing egg donors and surrogates. Personal Data may include your family history, lifestyle and social circumstances including age, date of birth, marital status, number of children, employment details, education/qualification, business contact details, gender, religion, race, health detail and other sensitive Personal Data. Answers to questions by Respondents, may also include Personal Data.
The purpose of collecting Personal Data as part of a registration will allow us to offer you as an egg donor or surrogate to intended parents who are registered with us.
For Users in the EEA, or for Users providing surveys to Respondents in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by British Surrogacy Centre User.
2.4.4. Geographical location
British Surrogacy Centre offers a number of data regions. A British Surrogacy Centre “Data Region” is a set of data centres located within a defined geographical area where User and Respondent data is stored. Personal Data is not transmitted between Data Regions. For British Surrogacy Centre Users with accounts located in British Surrogacy Centre’s European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in the respective country. For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.
2.4.4.1 Processing in the European Economic Area (EEA)
For Users with accounts located in British Surrogacy Centre’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and British Surrogacy Centre’s processing will take place in accordance with the GDPR.
2.4.4.1.1 Controller
British Surrogacy Centre processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
The British Surrogacy Centre entity which you as a User entered an agreement with when using British Surrogacy Centre’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section.
For Respondent data, as outlined in the “Collection of Respondent data” section, the User will be the Controller in accordance with Directive and GDPR, and British Surrogacy Centre will be the Processor.
British Surrogacy Centre adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, British Surrogacy Centre processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only.
All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
2.4.4.2 Processing in the United States Of America (US)
For Users with accounts in the British Surrogacy Centre US Data Region, British Surrogacy Centre processes data solely in data centres located in the US. British Surrogacy Centre has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in British Surrogacy Centre’s possession. British Surrogacy Centre will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.
All data collected by British Surrogacy Centre Users through web registrationd will be stored exclusively in secure hosting facilities provided by Microsoft and Godaddy web services. British Surrogacy Centre’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. British Surrogacy Centre’s policy is to protect and safeguard any personal information obtained by British Surrogacy Centre in accordance with United States state or federal laws governing the protection of personal information and data. Accordingly, British Surrogacy Centre adheres to practices and policies that aim to safeguard the data.
- Retention and deletion
British Surrogacy Centre will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Respondent data, British Surrogacy Centre’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Respondent data, Users with an active account will therefore have the responsibility to request the deletion data when required. When a users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
- Acceptance of these Conditions
We assume that all Visitors of our website, Respondents to registration forms powered by British Surrogacy Centre and users British Surrogacy Centre’s platform have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our website and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of British Surrogacy Centre website and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This privacy policy is an integral part of British Surrogacy Centre’s terms of use.
- Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to British Surrogacy Centre or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
6.British Surrogacy Centre’s Data Protection Officer
British Surrogacy Centre has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached by completing the form on our contact us page
- For Further Information
If you have any further questions regarding the data British Surrogacy Centre collects, or how we use it, then please feel free to contact us by using the contact form on our contact page