MY SURROGACY JOURNEY LTD DATA PRIVACY POLICY

  • Please read this policy carefully as it contains important information on who we are; how and why we collect, store, use and share personal information; your rights in relation to your personal information; and on how to contact us and supervisory authorities if you are concerned about our treatment of your data.

    This policy comprises the following sections:

    • Who we are and how to contact us
    • Our website
    • Our collection and use of your personal information
    • Our legal basis for processing your personal information
    • How and why we use your personal information
    • How long we keep your personal information
    • Who we share your personal information with
    • Where your personal information is held
    • Cookies 
    • Marketing
    • Your rights
    • Keeping your personal information secure
    • How to complain
    • Changes to this policy

     

    1. Who we are and how to contact us

    This website is operated By My Surrogacy Journey Ltd; we are a private limited company incorporated in England and Wales with registration number 12591701. Our registered office is at International House, 6 South Molton Street, Mayfair, London,W1K 5QF. You may also contact us by e-mail at contact@mysurrogacyjourney.com or by telephone to 07737 115 437. Please see more about us on the “About” tab on this website.

    We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation and the Data Protection Act 2018 (to which we refer as “Data Protection Law”) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

     

    2. Our website

    This policy relates only to use of our website, http://www.mysurrogacyjourney.com . In our website we may link to other websites owned and operated by certain trusted third parties in accordance with this policy. Such third party websites may also gather information about you in accordance with their own separate privacy policies; please consult those policies on the relevant third party website, as we cannot accept responsibility for the conduct of third parties.

     

    3. Our collection and use of your personal information

    We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website, complete customer surveys or participate in competitions via our website.

    The personal information we collect about you depends on the particular activities which you carry out through our website. Such information may include:

    • name, address and contact details
    • information to enable us to check your identity, such as your date of birth
    • bank account, credit/debit card, transaction, billing and payment details
    • details of any feedback you give us by phone, email, post or via social media
    • information about goods or services we provide to you 
    • your account details, such as username, login details
    • information from accounts you link to us, e.g. Facebook
    • information to enable us to undertake credit or other financial checks on you
    • Information about how you use our website, IT, communication and other systems
    • your responses to surveys, competitions and promotions

     

    We use this personal information to:

    • communicate with you
    • create and manage your account with us
    • verify your identity
    • perform our obligations
    • customise our website and its content to your particular preferences
    • notify you of any changes to our website or to our services that may affect you
    • notify you of particular events, activities and similar matters at My Surrogacy Journey Ltd 
    • improve our services

     

    This website is not intended for use by children under the age of 13 and we do not knowingly collect or use personal information relating to children.

    We collect most of this personal information directly from you through our website, in person, by telephone, text, email or social media, but we may also collect information from:

    • publicly accessible sources
    • third parties such as credit reference agencies;
    • third parties with your consent, such as your bank or building society
    • cookies on our website – for more information on our use of cookies, please see our Cookies Policy 
    • our IT systems, e.g.  access control systems, communications systems, email and instant messaging systems

     

    4. Our legal basis for processing your personal information

    Under Data Protection Law we may hold and use your personal information only if we have a proper reason for doing so. There are various different legal bases which may constitute a proper reason, depending on what personal information we process and why. These may include:

     

    • your consent: where you have given us clear consent for us to process your personal information for a specific purpose
    • contract: where our use of your personal information is necessary for a contract we have with you, or to take specific steps before entering into a contract with you
    • our legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
    • vital interests: where our use of your personal information is necessary to protect you or someone else’s life, health or safety
    • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party; a “legitimate interest” is a business or commercial reason to use your information which is not overridden by your own rights and interests.

     

    5. How and why we use your personal information 

    For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

    The table below explains what we use (process) your personal information for and our reasons for doing so:

    What we use your personal information for Our reasons
    To provide services to you For the performance of our contract with you or to take steps at your request before entering into a contract
    To obtain services from third party providers for the purposes of facilitating the performance of our obligations, e.g. payment or payroll service providers For our legitimate interests or those of a third party
    To prevent and detect fraud  For our legitimate interests or those of a third party, e.g. to minimise fraud that could be damaging 
    Marketing our services and those of selected third parties, including communicating news about My Surrogacy Journey Ltd, its events, activities and the like For our legitimate interests or those of a third party
    Conducting checks to identify our IP’s and verify their identity

    Other processing necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety regulation 

    		 To comply with our legal and regulatory obligations and to prevent fraud
    Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, to check capability 
    Ensuring business policies are adhered to, e.g. policies covering security, confidentiality and internet use For our legitimate interests or those of a third party
    Operational reasons, such as improving efficiency, training, ensuring safe working practices and quality control For our legitimate interests or those of a third party
    Statistical analysis to help us manage our business, eg in relation to our financial performance, client base, or other efficiency measures For our legitimate interests or those of a third party
    Preventing unauthorised access and modifications to systems so as to prevent and detect criminal activity that could be damaging  For our legitimate interests or those of a third party
    Creating, updating, maintaining and enhancing customer records For our legitimate interests or those of a third party and to comply with our legal and regulatory obligations

     

    6. How long we keep your personal information 

    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, 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.

     

     

    7. Who we share your personal information with

    We may share personal data with:

    • our advisers, for the purposes of obtaining their advice
    • third parties we use to help deliver services to you.
    • other third parties we use to help us run our business, e.g. marketing agencies or website hosts
    • law enforcement or other authorities if required by applicable law 
    • third parties approved by you, e.g. social media sites to which you choose to link your account or third party payment providers
    • our insurers and broker
    • our bank

    Except with your express consent, we will not share your personal information with any other third party and will not transfer your personal data outside the European Economic Area.

    We will always treat your personal information with the utmost respect and will never sell or licence it to other organisations.

    We will allow our service providers to handle your personal information which we supply to them only if we are satisfied that they will take appropriate measures to protect it.

     

    8. Where your personal information is held

    Your personal information may be held at our premises at at International House, 6 South Molton Street, Mayfair, London,W1K 5QF   or with third party agencies, service providers, representatives and agents as referred to above under  ‘Who we share your personal information with’.

     

    9. Cookies and similar technologies

    A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

    For further information on our use of cookies, please see our Cookies Policy.

    For further information on cookies generally visit https://ico.org.uk/for-the-public/online/cookies, www.aboutcookies.org or www.allaboutcookies.org.

     

    10. Marketing

    We would like to send you information about services which we provide, activities and events at My Surrogacy Journey, competitions and special offers and other matters concerning what we do, which we believe may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or social media.

    We will ask whether you would like us to send you such marketing messages only when you tick the relevant box on a form which you access while using our website.

    If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

    —contacting us at contact@mysurrogacyjourney.com or in writing to at International House, 6 South Molton Street, Mayfair, London,W1K 5QF

    —using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

    It may take up to ten days for this to take effect.

    For more information on your rights in relation to marketing, see ‘Your rights’ below.

     

    11. Your rights

    Under the Data Protection Laws you have a number of important rights free of charge. In summary, those include rights to:

     

    • fair processing of information and transparency over how we use your personal information
    • access to your personal information and to certain other supplementary information that this policy is already designed to address
    • require us to correct any mistakes in your information which we hold
    • require the erasure of personal information concerning you in certain situations
    • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
    • object at any time to processing of personal information concerning you for direct marketing
    • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
    • object in certain other situations to our continued processing of your personal information
    • otherwise restrict our processing of your personal information in certain circumstances

    For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

    If you would like to exercise any of those rights, please:

     

    • email or write to us in the manner described above under ‘Who we are and how to contact us’
    • let us have enough information to identify you  
    • if we so request, let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
    • let us know the information to which your request relates and any other information relevant to your  request

     

    12. Keeping your personal information secure

    We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

     

    13. How to complain

    We hope that can resolve any query or concern which you raise about our use of your information.

    Data Protection Law also gives you the right to lodge a complaint with the Information Commissioner, who may be contacted at https://ico.org.uk/concerns/ or telephone 0303 123 1113.

     

    14. Changes to this privacy policy

    This policy was published on 25th Feb 2021. 

    We may change this policy from time to time; if we make any material change relevant to your information we will inform you by communication to your contact details that you have provided to us. 

    If you have any questions about this policy or the information which we hold about you please contact us by e-mail to contact@mysurrogacyjourney.com or by telephone to 07737 115 437 or in writing to  at International House, 6 South Molton Street, Mayfair, London,W1K 5QF .