At Vitanova ApS ("Vitanova", "we", "us" or "our") we give high priority to confidentiality and data security. This privacy policy applies to our processing of personal data and establishes guidelines for the way Vitanova processes your personal data and provides you with the information that you are entitled to receive under applicable data protection laws.
This Privacy Policy covers both processing activities related to (i) IVF treatment under the trading name Vitanova and (ii) our sperm bank under the trading name Creovita.
You should read the Privacy Policy before you hand over your personal data to Vitanova.
1. Data controller and contact information
The data controller of your personal data regarding both IVF treatment (Vitanova) and the sperm bank (Creovita) is:
Vitanova ApS
Address: Vester Voldgade 106, 3., 1552 København V
CVR-no.: 32275400
E-mail: support@vitanova.dk
Phone number: +45 33 33 71 01
DPO:
DPO@ivirma.com
+45 33 33 71 01
2. From where do we obtain your personal data?
Vitanova may potentially obtain your personal data form the following sources:
Sperm bank
- Directly from you.
- Information collected when you fill out a donor application and book an appointment for submission of an initial sperm donation.
- If you wish to become a sperm donor at Vitanova, you must go through a special application and selection procedure. The first stage of the procedure is that you fill out an application form and book an appointment to submit an initial semen sample. We will also collect information via ongoing contact with you and each time you provide a new sample.
IVF treatment
- Directly from you and your partner both prior to treatment (for example when you are enquiring about services we provide or to provide diagnostic services) and during and post treatment.
- Medical records from other clinics or healthcare providers if approved by you.
For more details see the table below.
3. Purposes, categories of personal data, legal basis, and deletion
| Sperm Bank (Creovita) | |||||
| Processing activity | Which persons are covered? | What is the purpose? | Which categories of personal data is processed? | What is the legal basis for the processing? | When will the personal data be deleted? |
| Application process | Donor candidate |
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When you fill out the application form and book the appointment, we collect your name, date of birth, address, your contact information, and information about your appointment, as well as ask what type of donor you want to be and where you have heard about us. In addition, we ask which countries you have travelled to in the last 28 days, if any. The purpose is to be able to assess whether a quarantine period is necessary before you can begin the application process. When you show up for the initial semen test, we collect your full name and CPR number. The purpose of this is compliance with the legal requirements for record keeping. The results are recorded together with the name, date, and time of the submission of the sample, with the purpose of ensuring identification and efficient administration of the sperm sample and you as a donor candidate. Through your answers to the questionnaire, we process general information about you. This information is collected for the purpose of assessing your suitability as a donor at Vitanova. Through your answers to the questionnaire, we process sensitive information about you and your family’s physical and mental health, your sexual behavior, the occurrence of hereditary or chronic diseases in your family as well as information about your racial and ethnic origin. This information is collected for the purpose of assessing your suitability as a donor at Vitanova. When you show up for the clinical examination, we collect your full name and CPR number as well as a copy of your valid ID. When you fill out the application form and book the appointment, we collect your name, date of birth, address, your contact information, and information about your appointment, as well as ask what type of donor you want to be and where you have heard about us. When you show up for the initial semen test, we collect your full name and CPR number. The purpose of this is compliance with the legal requirements for record keeping. The results are recorded together with the name, date, and time of the submission of the sample, with the purpose of ensuring identification and efficient administration of the sperm sample and you as a donor candidate. Through your answers to the questionnaire, we process general information about you. This information is collected for the purpose of assessing your suitability as a donor at Vitanova. Through your answers to the questionnaire, we process sensitive information about you and your family’s physical and mental health, your sexual behavior, the occurrence of hereditary or chronic diseases in your family as well as information about your racial and ethnic origin. This information is collected for the purpose of assessing your suitability as a donor at Vitanova. When you show up for the clinical examination, we collect your full name and CPR number as well as a copy of your valid ID. We record our observations about your physical health, height, and weight, as well as characteristics such as eye color and hair color. We assess your psychological profile, e.g. through a psychosocial interview. In addition, you will be asked a few in-depth questions about your and your family's behavior and medical history. The purpose is to uncover your personal risk behavior and any hereditary diseases in your family. If you wish to be an ID Release donor and you are under the age of 25, you will be asked several detailed questions about your consideration of becoming an ID Release donor, and we note our assessment of your maturity level. The purpose is to ensure that you have considered your choice of donor type. We take a blood sample, and you must submit a urine sample, and in some cases a semen sample, which is tested for a number of infectious and hereditary diseases. Which specific diseases we test for depends on whether you want to be a No-ID Release or ID Release donor, as well as on the time of testing. You will receive information about which diseases you are tested for. |
Implementation of measures taken at your request prior to entering into an agreement with you, Article 6(1)(b) og the GDPR. Compliance with our legal obligation to ensure secure donor identification (Chapter 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR. Compliance with the statutory requirements for record keeping (Chapter 1 of the Executive Order on Record Keeping, cf. Article 8(1)(c) of the GDPR and ensuring secure identification of you (Chapter 6 of the Danish Tissue order, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data Protection Act. The legal basis for our collection of semen samples and processing of the analysis result is your explicit consent (section 21 of the Danish Tissue Executive Order and section 15 of the Danish Health Act and our legal obligation to assess your suitability as a donor (Chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. The legal basis for ensuring identification and efficient administration of personal data is our legal obligation to ensure secure donor identification (Chapter 6 of the Danish Tissue Executive order, cg. Article 6(1)(c) of the GDPR. The legal basis for the processing of general information about you is your explicit consent (Danish Health Act section 15) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (Chapter 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR. The legal basis for the processing of your sensitive information is your explicit consent (section 15 of the Danish Health Act) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. The legal basis for collection your full name and ID is compliance with the legal requirements to ensure secure identification of you, as well as to ensure traceability (Chapter 4 and 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data protection Act. The legal basis for the processing of information about your health from interviews is your explicit consent (section 21 of the Danish Tissue Executive Order and section 15 of the Danish Health Act), as well as compliance with our legal obligation to collect and store certain information for the selection of donors (chapter 6 of the Danish Tissue Executive Order and section 3.6 of Appendix 7, cf. Article 9(2)(b), (h) and (i) and Article 6(1) (c) of the GDPR. The legal basis for the collection of your sperm is your explicit consent (section 21 of the Danish Tissue Executive Order and Articles 9(2)(a) and 6(1)(a) of the GDPR). |
We store information that we have collected from you during the application procedure for 10 years from the last entry in your donor record, in accordance with the requirements for record-keeping obligation, section 15(1) of the Executive Order on Record Keeping, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. This only applies if you do not proceed from application to becoming a donor. Blood and urine samples are destroyed by our partners no later than 7-14 days after the sample have been taken. The initial semen sample is destroyed as soon as we have measured the motility of the semen, which is no later than 2-3 days after collection. |
| When you create and is in possession of a donor profile | Approved donor | To be able to create a description of you for a donor profile on our website. To continuously assess your suitability as a sperm donor To be able to administer you as a donor at Vitanova, including ensuring traceability of the donated sperm from the donation to distribution to the recipient. To describe you in your donor profile. |
The following information will appear on your profile:
The results of the tests made for infectious and genetic diseases. If you choose to be a donor with an extended profile, the following information will be collected and appear in the donor profile on our website:
With each donation, we note the volume of sperm, the concentration of sperm cells and the proportion of motile sperm cells. We ask if you have been ill or if there have been changes in your travel or risk behavior since the last donation. Finally, we regularly take blood samples and ask you to submit urine and, in some cases, semen samples, which we test for various infectious and hereditary diseases. Once you have been approved as a donor, we will continue to retain the sensitive information we previously collected about you for the then purpose of assessing your initial suitability as a donor. The purpose of the future storage is to be able to document and ensure traceability in relation to our compliance with the legal requirements for the suitability assessment, if a communicable disease is detected in a person created using donor sperm and/or a legal claim is made against Vitanova’s in connection therewith. The DNA material that was taken from your blood and urine samples may be used for further tests with the aim of uncovering other hereditary diseases in addition to those tested for as part of your initial donor suitability assessment, including determining your suitability as a donor either in general or in relation to a specific, potential recipient of your sperm: To be able to pay compensation to you, we process your bank details. We may need to use your telephone number and email address to contact you, e.g. to make an appointment for the statutory blood tests, or because your test results show conditions that we need to inform you about. If a serious adverse reaction or adverse event should occur in connection with the distribution of your semen, e.g. the discovery of hereditary diseases in you or in a child created using sperm from you, we may process additional relevant health information about you for the purpose of investigating the serious side effect/adverse event. Once you have become a donor, we use your CPR number or other relevant ID to ensure unique identification of you. |
The legal basis for processing information on your donor profile is the fulfillment of the donor agreement you have entered into with Vitanova’s (Article 6(1)(b) of the GDPR). The legal basis for the processing of the photos and/or video recordings you provide to us, and the other general personal data that you provide when filling in the "extended profile form" is the performance of the agreement you have entered into with us (Article 6(1)(b) of GDPR). The legal basis for the processing of 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 GDPR). The legal basis for the processing of your photo is fulfillment of the incoming donor agreement (Article 6(1)(b) of the GDPR). The legal basis for the ongoing assurance that you are suitable as a donor is compliance with our legal obligation to carry out this ongoing assurance of your suitability (Chapter 6 of the Danish Tissue Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR). The legal basis for our continued processing of the personal data previously collected thus changes to the requirement to ensure traceability (Chapter 4 of the Danish Tissue Executive Order and Annex 1, Section E.1. cf. Article 9(2)(b), (h), (i) and (f) and Article 6(1)(c) of the GDPR). The legal basis for the processing of your DNA material is your explicit consent (section 15 of the Danish Health Act and Article 9(2)(a) and Article 6(1)(a) of the GDPR) as well as compliance with our legal obligation to process and disclose information in the event of serious side effects/adverse events (Chapter 6 of the Danish Tissue Act and Chapter 7 of the Danish Tissue Executive Order cf. Article 9(2) of the GDPR, (b), (h) and (i) and Articles 6(1) (c) and (f). The legal basis for collection your full name and ID is compliance with the legal requirements to ensure secure identification of you, as well as to ensure traceability (Chapter 4 and 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data protection Act. The legal basis for the processing of information about your health from interviews is your explicit consent (section 21 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and section 15 of the Danish Health Act), as well as compliance with our legal obligation to collect and store certain information for the selection of donors (chapter 6 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and section 3.6 of Appendix 7, cf. Article 9(2)(b), (h) and (i) and Article 6(1) (c) of the GDPR. The legal basis for the collection of your eggs is your explicit consent (section 21 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and Articles 9(2)(a) and 6(1)(a) of the GDPR). The legal basis for our collection of eggs is your explicit consent (section 21 of the Danish Tissue Executive Order, and section 15 of the Danish Health Act and our legal obligation to assess your suitability as a donor (Chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. The legal basis for ensuring identification and efficient administration of personal data is our legal obligation to ensure secure donor identification (Chapter 6 of the Danish Tissue Executive order, cg. Article 6(1)(c) of the GDPR. The legal basis for the processing of general information about you is your explicit consent (Danish Health Act section 15) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (Chapter 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR. The legal basis for the processing of your sensitive information is your explicit consent (section 15 of the Danish Health Act) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. |
We store the information we have collected about you, including health information, information about your sexual behavior and information about your racial and ethnic origin, for a minimum of 30 years from the last distribution of your sperm on the basis of the requirements of the Danish Tissue Executive Order for traceability and assessment of serious side effects that may occur in donor children, as well as for documentation purposes. If your sperm is distributed and used in a country other than Denmark, national rules for ensuring traceability may apply in the receiving country, which require Vitanova to store your information for a longer period than 30 years from the last distribution of your sperm. The retention period will thus be determined on the basis of the national rules of the recipient country. We store bookkeeping information for 5 years from the end of the relevant financial year in accordance with the rules on documentation in the Danish Bookkeeping Act. This is all information necessary to document our bookkeeping, e.g. your bank details and documentation of compensation paid to you during your time as a donor. Blood, urine and semen samples are destroyed by our partners as soon as the necessary tests have been completed, no later than 7-14 days after he sample has been taken. We store sperm for as long as we assess that it is possible to use it for fertility treatment or for research purposes, if you have also consented to this. |
| IVF treatment (Vitanova) | |||||
| Processing activity | Which persons are covered? | What is the purpose? | Which categories of personal data is processed? | What is the legal basis for the processing? | When will the personal data be deleted? |
| Fertility enquiries | Enquiries that do not lead to treatment | Assess whether request possible. | Contact information health information. | Implementation of measures taken at your request prior to entering into an agreement with you, Article 6(1)(b) of the GDPR. | If an enquiry do not lead to treatment, Vitanova will store the data for 6 months. If you have been at Vitanova for an exam or test but don’t undergo treatment, we will store your data for 10 years. |
| Fertility assessment/fertility treatment | Patients who want to undergo treatment at Vitanova |
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When you fill out the application form and book the appointment, we collect your name, date of birth, address, your contact information, and information about your appointment, as well as ask what type of donor you want to be and where you have heard about us. In addition, we ask which countries you have travelled to in the last 28 days, if any. The purpose is to be able to assess whether a quarantine period is necessary before you can begin the application process. We collect data about the result of your treatment. This is for the purpose of recording the outcomes of your treatment and for internal statistics. We are required to report all treatments as well as the outcome of the treatments, to the Danish authorities, the information is reported in an anonymized version. When using donor sperm, Vitanova is obligated to report positive outcomes of treatments to the sperm banks. This is to keep clear traceability and to ensure that the number of children born from each donor doesn’t exceed limits set out in relevant legislation. Vitanova is also obligated to report any serious adverse reactions or serious unwanted events to the authorities. Your information can, with your approval, be shared with third parties in cases where an investigation is needed if a child born from treatment with donor sperm or donor eggs is born with a potentially hereditary disease. |
Implementation of measures taken at your request prior to entering into an agreement with you, Article 6(1)(b) of the GDPR. Compliance with our legal obligation to ensure secure donor identification (Chapter 6 of the Danish Tissue Executive Order and chapter 6 of the Danish Act on Artificial Insemination, cf. Article 6(1)(c) of the GDPR. Compliance with the statutory requirements for record keeping (Chapter 1 of the Executive Order on Record Keeping, cf. Article 8(1)(c) of the GDPR and ensuring secure identification of you (Chapter 6 of the Danish Tissue order and the Danish Act on Artificial Insemination, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data Protection Act. The legal basis for our collection of your eggs is your explicit consent (section 21 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and section 15 of the Danish Health Act. The legal basis for ensuring identification and efficient administration of personal data is our legal obligation to ensure secure identification (Chapter 6 of the Danish Tissue Executive order, the Danish Act on Artificial Insemination cf. Article 6(1)(c) of the GDPR. The legal basis for the processing of general information about you is your explicit consent (Danish Health Act section 15) and compliance with our legal obligation to collect and store certain information for the assessment (Chapter 6 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination, cf. Article 6(1)(c) of the GDPR. The legal basis for the processing of your sensitive information is your explicit consent (section 15 of the Danish Health Act) and compliance with our legal obligation to collect and store certain information for the assessment (chapter 6 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. The legal basis for collection your full name and ID is compliance with the legal requirements to ensure secure identification of you, as well as to ensure traceability (Chapter 4 and 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data protection Act. The legal basis for the processing of information about your health from interviews is your explicit consent (section 21 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and section 15 of the Danish Health Act), as well as compliance with our legal obligation to collect and store certain information for the selection of donors (chapter 6 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and section 3.6 of Appendix 7, cf. Article 9(2)(b), (h) and (i) and Article 6(1) (c) of the GDPR. The legal basis for the collection of your eggs is your explicit consent (section 21 of the Danish Tissue Executive Order, the Danish Act on Artificial Insemination and Articles 9(2)(a) and 6(1)(a) of the GDPR). The legal basis for our collection of eggs is your explicit consent (section 21 of the Danish Tissue Executive Order, and section 15 of the Danish Health Act and our legal obligation to assess your suitability as a donor (Chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. The legal basis for ensuring identification and efficient administration of personal data is our legal obligation to ensure secure donor identification (Chapter 6 of the Danish Tissue Executive order, cg. Article 6(1)(c) of the GDPR. The legal basis for the processing of general information about you is your explicit consent (Danish Health Act section 15) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (Chapter 6 of the Danish Tissue Execu-tive Order, cf. Article 6(1)(c) of the GDPR. The legal basis for the processing of your sensitive information is your explicit consent (section 15 of the Danish Health Act) and compliance with our legal obligation to collect and store certain information for the assessment and selection of donors (chapter 6 of the Danish Tissue Executive Order, cf. Article 9(2)(b), (h) and (i) and Article 6(1)(c) of the GDPR. |
Vitanova will store your medical records obtained doing your treatment for at least 10 years. Vitanova is obligated to keep the data for at least 30 years after the last use of gametes if the treatment has included the use of a sperm donor or egg donor. |
| Egg donation | Egg donor applicants and approved egg donors at Vitanova. | To assess if an egg donor applicant can be approved as an egg donor. To keep full traceability between egg donor and recipient. |
Name, birthday, contact details, height, weight, occupation, family relations, picture ID. Health information, test results ethnicity, genetic data, sexual relationships/orientation. To track potential risk behavior, you will be asked about your travel plans, recent health problems, new relationships, piercings/tattoos and medication as well as vaccinations. We keep records of the outcome of donor cycles, including number of eggs donted. If you are an ID-release donor, your identity will be shared with children born after treatment with the use your eggs. If a child is born, with a potential hereditary disease after treatment using your eggs, we will have to do an investigation. In these cas-es, your information can, with your acceptance, be shared with third parties such as genetic consultants, test laboratories etc. |
The legal basis for collection your full name and ID is compliance with the legal requirements to ensure secure identification of you, as well as to ensure traceability (Chapter 4 and 6 of the Danish Tissue Executive Order, cf. Article 6(1)(c) of the GDPR and section 11(2)(1) of the Danish Data protection Act. The legal basis for the processing of information about your health from interviews is your explicit consent (section 21 of the Danish Tissue Executive Order and section 15 of the Danish Health Act), as well as compliance with our legal obligation to collect and store certain information for the selection of donors (chapter 6 of the Danish Tissue Executive Order and section 3.6 of Appendix 7, cf. Article 9(2)(b), (h) and (i) and Article 6(1) (c) of the GDPR. The legal basis for the collection of your eggs is your explicit consent ( Executive Order regarding Assisted Reproduction and Articles 9(2)(a) and 6(1)(a) of the GDPR). |
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4. Transfer to separate data controllers and entrustment to data processors
In certain circumstances, it may be necessary to transfer your personal data to the following categories of recipients:
| Sperm Bank (Creovita) | ||
| Categories of recipients | Category of data subject and types of personal data | Legal basis |
| Customers | Information about how many units of sperm we hold from a specific donor and whether a donor is still active, or it is expected that additional units of sperm will become available. | The legal basis for the collection and disclosure of these information is our legitimate interest in being able to distribute donor sperm to the countries whose legislation contains these requirements (Article 6(1)(f) of the GDPR). |
| Fertility clinics and relevant national authorities | The information about you that appears in the donor profile, including test results for infectious and genetic diseases. In some cases, if deemed professionally relevant, we may share excerpts or entire test reports with fertility clinics. | The legal basis for the collection and disclosure of these information is our legitimate interest in being able to distribute donor sperm to the countries whose legislation contains these requirements (Article 6(1)(f) of the GDPR). |
| Donor children and the children’s parents (some countries) | What information is provided from here and the timing of it varies according to the individual country's legislation. You will receive more information about this if it is relevant in relation to the distribution of your sperm. | The legal basis for the collection and disclosure of these information is our legitimate interest in being able to distribute donor sperm to the countries whose legislation contains these requirements (Article 6(1)(f) of the GDPR). |
| Other tissue establishments | The stock of your donated sperm and other personal data covered by traceability requirements will be transferred. | Section 11 of the Danish Tissue Executive Order cf. Article 6(1)(c) of the GDPR. |
| In some countries, it is a legal requirement that the donor is alive at the time the sperm is dispensed from Vitanova or used for treatment. When we deliver donor sperm to these countries, we will therefore look up the CPR register to check whether the donor in question is alive when the sperm is shipped from Vitanova and in connection with treatment. | Information on whether you are alive at the time of dispensing your sperm. | The legal basis for the collection and disclosure of the above information is our legitimate interest in being able to distribute donor sperm to the countries whose legislation contains these requirements (Article 6(1)(f) of the GDPR). |
| If Vitanova ceases to operate as a tissue establishment, the stock of your donated sperm as well as other personal data subject to traceability requirements will be transferred to another tissue establishment. | Your donated sperm, and all information related to the donated sperm. | Section 11 of the Danish Tissue Executive Order cf. Article 6(1)(c) of the GDPR. |
| IVF treatment (Vitanova) | ||
| Categories of recipients | Category of data subject and types of personal data | Legal basis |
| Fertility clinics and relevant national authorities | In case you wish to transfer frozen gametes, you have in storage at Vitanova to another clinic for treatment, Vitanova will disclose information about your gametes to the receiving tissue establishment. If you wish to have your medical records sent to another clinic, we will only do this after receiving written consent from you. |
The legal basis for the transfer of these information is our legitimate interest in being able to store your eggs (Article 6(1)(f) of the GDPR). |
| If Vitanova ceases to operate as a tissue establishment, the stock of your donated sperm as well as other personal data subject to traceability requirements will be transferred to another tissue establishment. | All information that we are required by law to keep for either 10 years or 30 years. | The legal basis for the transfer of these information is our legitimate interest in being able to store your eggs (Article 6(1)(f) of the GDPR). |
Your personal data will not as a starting point be transferred to data controllers established in countries outside the EU/EEA that do not have an adequate level of protection unless we obtain your prior consent. However, if you are a donor, your donor profile will be available to anyone who registers as a user on our website. This also includes persons residing in countries outside the EU/EEA. This means, that the information available on the website also will be available outside the EU/EEA.
If you have chosen to be an ID Release Donor, Vitanova will disclose your name, date of birth and your last address to persons who have reached the age of 18 and who can prove with a significant degree of certainty that they were created using sperm from you.
5. Transmission to data processors
To achieve the above purposes, we may give third parties access to your personal data, which, based on a contractual relationship with Vitanova, provides relevant services, this could be IT suppliers or other suppliers that process personal data for us. Such suppliers will only process personal data in accordance with our instructions according to the signed data processing agreements.
Your personal data will not be transferred to data processors established in countries outside the EU/EEA that do not have an adequate level of protection unless we obtain your prior consent.
6. Your rights
- You have the right to access the personal data we process about you with some exemptions.
- You have the right to object to our collection and further processing of your personal data.
- You have the right to rectification and deletion of your personal data, however there are certain statutory exceptions that may exclude you from these rights.
- You have the right to ask us to restrict the processing of your personal data.
- In certain circumstances, you may also request to receive a copy of your personal data and to transmit the personal data you have provided to us to another data controller (data portability).
- You can withdraw any consents you may have given at any time. We will then delete your personal data unless we may continue the processing on another basis as further stated below.
7. Withdrawal of consent
To the extent that Vitanova's processing of your personal data is based on consent, you can withdraw your consents at any time. You do this by sending an email to support@vitanova.dk.
If you wish to withdraw your consent, please note the following:
Any withdrawal of your consent does not affect the lawfulness of Vitanova's processing of your information based on your previously given consent up to the time when the consent is withdrawn. If you withdraw your consent, this decision will only take effect from the time of withdrawal.
Withdrawal of consent can only take place until the time when the processing covered by the consent has been 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 once the completed donor profile has been made and the preparation of this has been completed.
Any withdrawal of your consent will also not affect Vitanova's processing of the information that we already process or may further process based on another legal basis, e.g. for the fulfillment of the donor agreement entered into between Vitanova and you, or for the purpose of complying with our legal obligations to, for example, record keeping or ensuring traceability of the donated sperm from the donation to distribution to the recipient.
Whether withdrawal of consent entails deletion of your information must therefore be determined according to the specific circumstances at the time consent is withdrawn and depends on the legal basis on which we process your information.
Regarding withdrawal of consent to sperm samples already provided, the right to withdraw consent is only applicable up until the point of distribution.
8. Questions and complaints
If you have any questions about this privacy policy or if you wish to complain about the way we process your personal data, please feel free to contact us:
Vitanova ApS
Address: Vester Voldgade 106, 3., 1552 København V
E-mail: support@vitanova.dk
Phone number: +45 33 33 71 011
If your complaint is not resolved by us and you want to proceed with the case, you can complain to the Danish Data Protection Agency:
The Danish Data Protection Agency
Carl Jacobsens Vej 35
2500 Valby
Phone number: +45 33 19 32 001
E-mail: dt@datatilsynet.dk