Privacy Policy
Introduction
Welcome to SEEN’s privacy policy.
SEEN aims to provide you with the information that you need in order to make fully informed decisions relating to your fertility treatment and care. We provide detailed ratings and reviews for clinics so that you can decide which providers best suit your particular needs. In accessing and using our services we may use your personal data, such as choosing to provide a review of a clinic, browse our website, using our Fertility Passport service and/or register for an account with us.
SEEN respects your privacy and is committed to protecting your personal data whenever and however we use it. This privacy policy will explain what is meant by your personal data, as well as informing you as to how we look after and use it, and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy provides you with an explanation of how SEEN collects and processes your personal data. Personal data is any information from which you can be identified, whether directly or indirectly, such as your name, contact details, or other unique identifiers.
We will collect and use your personal data in a variety of ways. In particular, we collect and use your data when you;
(i) provide us with a review about a clinic;
(ii) browse and use our website, including the postcode search facility;
(iii) subscribe to receive our newsletter;
(iv) create an account with us;
(v) purchase our specialist guides; and
(vi) use the Fertility Passport service
Under data protection law, the ‘controller’ is the organisation responsible for ensuring that your personal data is used lawfully and appropriately. SEEN is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Kayleigh Hartigan using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact ourdata privacy manager in the following ways:
Full name of legal entity: Fertility Mapper Limited
Email address: hello@fertilitymapper.com
Postal address: 9 Bonhill Street, London, United Kingdom, EC2A 4DJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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 [09.07.25].
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
This 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 our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
As set out above, 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 unique identifiers relating to you have been removed (anonymous data). For example, we do not include your name, address, or other details from which you can be identified in the published versions of your reviews to ensure that they are fully anonymised.
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 billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Health Data includes information about your medical background and the outcome of test results, specifically in relation to your use of the Fertility Passport service (as explained in further detail below).
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products 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 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 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.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us online, via our website, by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services, including the Fertility Passport;
- create an account on our website;
- leave a review on our website;
- opt in for our mailing list;
- opt in and sign up for our newsletter;
- purchase a guide on our website;
- report a review left on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks such as Google based outside the UK; and
(c) search information providers such as Google based outside the UK.
4. How we use your personal data
In order to use your personal data, we must do so ‘lawfully’. This means we must satisfy what is known as a ‘lawful basis’ under the data protection legislation. 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. We have also identified what our legitimate interests are where appropriate.
Special Categories of Personal Data
We process special categories of personal data in accordance with Article 9 of the UK General Data Protection Regulation (‘GDPR’), when you leave a review on our website, including when you provide us with information to enable us to verify your review. ‘Special categories of personal data’ are a more sensitive form of personal data according to data protection legislation, and attract additional protection. In particular, we must satisfy an additional lawful basis in order to use any personal data which. Special category data includes personal data revealing:
- Racial or ethnic origin;
- Religious or philosophical beliefs;
- Genetic data;
- Data concerning health; or
- Data concerning a natural person’s sex life or sexual orientation.
Unless you are using the Fertility Passport service, which is covered in further detail below, the only special categories of personal data we will process about you is in the specifics of your treatment which you provide when leaving a review and if you complete our review verification document and/or provide additional information for the purpose of enabling us to verify your review. For the avoidance of doubt, however, your reviews will only be published in anonymised format, such that your special category data is only identifiable to us and not other users of our services and the contents of your review verification document and any other information you provide to us for the purpose of verifying your review will not be published. In order to hold that data about you we rely your explicit consent to do so.
Fertility Passport
The Fertility Passport is a unique and bespoke service we offer in order to match you with the most suitable clinics and to streamline the onboarding process with them to enable more effective consultations. The Fertility Passport operates as follows:
- You may have been directed to the Fertility Passport via a range of different routes, including from third party websites (such as clinics) or the Fertility Mapper website. The first step will be for you to fill in an initial questionnaire with some background details, including your treatment history to date. We will collect your email address and set up an individual Fertility Passport account for you;
- We will then, based on your answers, match you to a long list of potentially suitable clinics and then email that list to you. We will invite you to select your preferred three clinics;
- Once we receive your preferred three clinics you will then be invited to book, and pay for, blood tests, scans and semen analysis (as applicable). This is to ensure that you do not have to undertake three separate sets of tests with the individual clinics, as we have agreed with the clinics that will accept the tests we carry out on your behalf. You will pay us for those tests, which will be carried out by a trusted third party provider;
- Once we have received the test results back we will then check against your list of preferred three clinics to confirm whether they are an appropriate match for you. If they are then we will proceed to the following step and if not then we will invite you to update your shortlist of preferred clinics;
- We will then liaise with your confirmed shortlist of clinics to book you in for initial consultations with them – it is up to you how many initial consultations we arrange, up to a maximum of three. You will also be invited to complete a more detailed questionnaire with additional medical information – we will share that completed questionnaire with the clinic(s), if you consent to us doing so;
- You will then proceed to undergo your initial consultations with the clinic(s). Any information provide to them, whether by us or by yourself directly, will be managed in accordance with their own privacy policy;
- We will contact you following the initial consultation(s) to collate any feedback of your experience. We will share that feedback with the clinic(s), if you agree to us doing so;
- It will then be for you to decide whether you wish to proceed with treatment, and if so with which clinic; and
- If you do undertake treatment then we will invite you to review your experience via Fertility Mapper. As per that overview we will only share your health data with clinics if you explicitly consent to us doing so.
As per that overview we will only share your health data with clinics if you explicitly consent to us doing so.
Marketing
You will receive marketing communications from us if you have consented to us doing so, joined our mailing list, signed up for an account, signed up to our newsletter or purchased goods or services from us and you have not opted out of receiving that marketing. You may opt out of communications from us by unsubscribing from the footer of any email you receive from us or by contacting us with your request at hello@fertilitymapper.com at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Where you opt out of receiving marketing messages, either from us or third parties, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies and similar technologies
A cookie is a small piece of information that is placed on your computer when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers.
When you first visit our sites using a new browser, or if you visit in private browsing mode, we will provide you with a cookies permission banner seeking your consent to use of cookies as required by law. From this banner you will be able to access our cookies management tool. By clicking OK or clicking through to any part of the site, we will start to manage your visit using cookies.
We use the following types of cookie, as will your browser:
- Analytics cookies that remember your computer or mobile device when you visit our website and recognise visits to our website across different devices. They keep track of browsing patterns and help us to build up a profile of how our readers use the website. We use that information for customer analytics and to serve advertisements that we think might be of particular interest to you on our and other websites.
- Service cookies that help us to make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; to detect what device you are using and adapt how we present our services according to the screen size of that device; and meter the number of pages you view for the purpose of administering subscriptions to FertilityMapper.
- Third party advertising and analytics cookies, which are placed by or on behalf of independent advertisers who are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site by us or by your browser. They can allow the advertiser or your browser to tailor advertising to you when you visit other websites. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once, to make sure you are not repeatedly served with the same advertising messages.
- We also place third party cookies to enable the serving of our own advertisements, for example, for our subscriptions offers, on other websites. These advertisements will be based on your browsing behaviour on our website and will be tailored to your interests. The information we gather from your visit is limited to page URLs.
We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.
Managing your cookies and preferences
Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site.
We also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is our cookie management tool:
We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below, to view their websites and privacy policies.
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.
5. Sharing your personal data
We will not usually share your personal data with third parties. We will, however, share your personal data with the following:
- Clinics in circumstances where you are using the Fertility Passport service and agree to us sharing your personal data.
- Service providers (acting under our specific instructions as processors) who provide IT and system administration services or specialist services (notably blood or semen analysis if you are using the Fertility Passport service).
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
6. International transfers
We do not transfer your personal data outside the UK.
7. 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.
8. 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.
By law we have to keep basic information about our website users (including Contact, Identity, Financial and Transaction Data) for six years after you cease being a user. Where you have created an account on our website and have decided to close your account, your personal data will be held for up to an additional six months, unless you consent to us sending you marketing material.
In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for ongoing use, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
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.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Explicit Consent means processing your personal data where consent has been expressly confirmed in words.