Privacy Notice

Zita West Clinics Ltd and Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”) and Zita West Products Limited are committed to respecting and protecting your privacy. This notice tells you about how we process your personal data and how we use and may share it. We will only process your personal data in accordance with this Privacy Notice and any other information we may give you about how we process your personal data, which will comply with the current data protection legislation. We do not share any of our patient’s or customers personal data with any 3rd party organisations other than for the purposes of processing the data for use in relation to the marketing and provision of Zita West Clinic services or the marketing and provision of Zita West products.In this Notice the terms “personal data”, “Data Controller”, “Data Processor” each have a special meaning that is defined by the Data Protection Act 1998 and, from the date it comes into force in May 2018, the EU General Data Protection Regulation (2016/679).

Who We Are

Zita West Clinics Ltd and Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”):

The Zita West Clinic is a private health clinic offering preconception planning, natural fertility advice and treatments and IVF treatment. The Zita West Clinic is owned by CARE Fertility Limited, which is a provider of IVF treatment, licenced by the HFEA (Human Fertilisation & Embryo Authority). The Zita West Clinic comprises two operating companies, Zita West Clinics Ltd and Zita West Assisted Fertility Ltd, both trading as The Zita West Clinic.

Zita West Products Ltd:

Zita West is a midwife, fertility expert and consultant and author on books to do with getting and being pregnant. Zita West Products Ltd is a retailer and wholesaler of the Zita West brand of specialist food supplements designed to help support the nutrition of women and men during preconception and women during pregnancy and the post-natal period. We have a specialist multivitamin and multibiotic supplement for children. The company also produces a range of cosmeceuticals designed for use by women during pregnancy and after the birth.

Your Data Controller

Zita West Clinics Ltd and Zita West Assisted Fertility Limited (trading as “The Zita West Clinic”):

Zita West Clinics Ltd and Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”) are Data Controllers in relation to all personal data provided by you or by others about you to either company. The Data Protection Officer for both companies is Anita O’Neill, who can be contacted by email at anita@zitawest.com or by telephone on 020.7224.0017.

Zita West Products Ltd:

Zita West Products Ltd is a Data Controller in relation to all personal data provided by you or by others to Zita West Products Ltd. The Data Protection Officer is Brian Astley, who can be contacted by email at brian@zitawest.com or by telephone on 01280 707 401.

Information We Collect About You

Zita West Clinics Ltd and Zita West Assisted Fertility Limited (trading as “The Zita West Clinic”):

The personal data we would like to process and collect from you is:

Personal data type: Source
 Your IP address and operating system browser type  Browsing data collected on WP Engine (WordPress) from visitors to our website
 Some social media providers, and particularly Facebook and Google, do not provide us with personal data about you but they may use this to present our advertising to you online based on your user and visits profile Facebook
Google
YouTube
 Your name, telephone number(s), email address, postal address  Provided either online or by telephone by the prospective patient/patient when booking an appointment or registering for attendance at a Clinic Open Evening or event
 Your name, telephone number(s), email address  Provided online by the registrant in registering for a webinar
 Provided online by the registrant in signing up to receive either an e.newsletter or e.marketing material via the Zita West website (vlogs/blogs/tweets)
 Your appointment history  Compiled by recording your individual appointments
 Your age, gender, ethnicity, sexual orientation, marital status, parental status, fertility/pregnancy status and medical history Provided either online and/or by telephone and/or by post via emails, notes and questionnaires completed by the prospective patient/patient when booking an appointment and in preparation for a consultation or provided during a consultation and recorded in the patient’s notes
 Your consent to treatment(s)  Provided in signed consent forms for specific aspects of any licenced treatment(s) you choose to receive at the Clinic
 Your Credit/debit card details  Provided either online or by telephone by the prospective patient/patient when booking an appointment/consultation or buying Zita West products/books from the Clinic. Not held/retained by Zita West Clinics Ltd or Zita West Assisted Fertility Ltd. Held/retained remotely by Lloyds Bank in encrypted form
 Your bank account details Provided online as a result of a direct payment to the Clinic made via your bank. Data visible on paper statements and online but only by by authorized Zita West Clinic staff following passcode protected login to the bank accounts of Zita West Clinics Limited or Zita West Assisted Fertility Ltd

The personal data we collect will be used for the following purposes. We are committed to ensuring that the information we collect is appropriate for these purposes and does not constitute an invasion of your privacy:
• 1. To ensure our website is presented in the most effective manner for customers and their computers
• 2. To register your details for attendance at a Clinic Open Evening or Event or Webinar and to communicate with you about the arrangements for it and any changes to those arrangements
• 3. To record any relevant information about you and/or your partner’s age, gender, ethnicity, sexual orientation, marital status, parental status, fertility/pregnancy status and medical history as may be relevant to a consultation or consultations and a treatment or treatments at the Clinic. Some of this information will be shared with CARE Fertility London Ltd as part of the delivery of assisted conception treatment. CARE Fertility London Ltd are required to share some of this information with the Human Fertilisation & Embryo Authority (HFEA) as part of the mandatory requirement for the recording and reporting of licenced assisted conception treatments.
• 4. The handling and response to any queries you may have about our services and any advice given or medication or treatments prescribed.
• 5. The payment or refunding for/of any appointments, consultations, medications, products or treatments provided by the Clinic.
• 6. Subject to your explicit permission, which can be withdrawn at any time, the communication with you of general marketing information about natural fertility and/or assisted conception and/or about the Zita West Clinic specifically.
• 7.Subject to your explicit permission, which can be withdrawn at any time, the digital delivery of newsletters/mailers containing updates on relevant research and development about nutritional supplements for preconception, pregnancy and the post-natal period generally and on the Zita West product range specifically.

Our Legal Basis for Processing Your Personal Data

Our legal basis for processing your personal data is:
• 1 by your explicit consent to our use of cookies on our website.
• In the case of 2: by your voluntary provision of your contact details for the purpose described, and in the case of 3, 4, 5, 6 and 7: by your explicit consent, provided separately online for each proposed category of use.

The Special Categories of Personal Data Concerned

The special categories of personal data concerned are:
• Details of age, gender, ethnicity, sexual orientation, marital status, parental status, fertility/pregnancy status and medical history provided by the prospective patient/patient as may be relevant for a consultation or consultations and a treatment or treatments provided by the Clinic and/or Zita West products retailed by the Clinic.

Zita West Products Ltd:
The personal data we would like to process and collect from you is:

Personal data type: Source
Your IP address and operating system browser type Browsing data collected on WP Engine (WordPress) from visitors to our website
Some social media providers, and particularly Facebook and Google do not provide us with personal data about you but they may use this to present our advertising to you online based on your user and visits profile Facebook
Google
YouTube
Your name Provided either online or by telephone by the customer when placing an order
Provided online by the registrant in registering for a webinar
Provided online by the registrant in signing up to receive either an e.newsletter or e.marketing material via the Zita West website
Your order history Compiled by recording your individual orders
Your telephone number(s) Provided either online or by telephone by the customer when placing an order
Your postal address Provided either online or by telephone by the customer when placing an order
Your email address Provided either online or by telephone by the customer when placing an order
Provided online by the registrant in registering for a webinar
Provided online by the registrant in signing up to receive either an e.newsletter or e.marketing material via the Zita West website
Your Credit/debit card details Provided either online or by telephone by the customer when placing an order. Not held/retained by Zita West Products Ltd. Held/retained remotely by SagePay in encrypted form
How many weeks pregnant you are Provided either online or by telephone by the customer when placing an order for pregnancy related products and requesting our automatic reordering service

The personal data we collect will be used for the following purposes . We are committed to ensuring that the information we collect is appropriate for these purposes and does not constitute an invasion of your privacy:
• 1.To ensure our website is presented in the most effective manner for customers and their computers
• 2. The fulfillment and delivery of any orders you place with us
• 3. The handling and response to any queries you may have about our products and the status of your order
• 4. The payment or refunding for/of any orders you place with us
• 5. The recording of your order history with us
• 6. Based on your order history, the communication with you of other products or services provided by Zita West Products Ltd that we think may be of interest to you.
• 7. Subject to your explicit permission, which can be withdrawn at any time: the digital delivery of newsletters/mailers containing updates on relevant research and development about nutritional supplements for preconception, pregnancy and the post-natal period generally and on the Zita West product range specifically
• 8. Subject to your explicit permission, which can be withdrawn at any time:
for sharing with Zita West Clinics Ltd and Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”), who are specialist providers of clinical services relating to natural and assisted fertility and conception, for the communication with you of services provided by Zita West Clinics Ltd and Zita West Assisted Fertility Ltd and/or developments relating to natural fertility and conception and assisted fertility and conception generally.

Our Legal Basis for Processing Your Personal Data

Our legal basis for processing your personal data is:
• 1 by your explicit consent to our use of cookies on our website.
• In the case of 2, 3, 4 and 5: the contract between us for the supply and delivery of our products to you
• In the case of 6, 7 and 8: your explicit consent, provided by your confirmation that you want to receive these communications, your consent for each of which has been provided separately.

The Special Categories of Personal Data Concerned

The special categories of personal data concerned are:
• Details of age, gender, general health and fertility health and history provided by the customer as background to requests for information/guidance on the suitability or recommended use of our products and/or as background to the main fertility related issues and concerns of registrants for webinars to allow better targeting of the webinar content
• Numbers of weeks pregnant for those customers who are pregnant and who want to sign up for our automatic reordering service

Consent

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd and Zita West Products Limited (trading as “The Zita West Clinic”):

Consent is required for Zita West Clinics Limited and Zita West Assisted Fertility Limited to process any personal data that is not authorised by contract, and this must be explicitly given by you. Where we may ask you for personal health related data we will make it clear why and how the information will be used.

You may withdraw consent at any time by sending an email to clinics@zitawest.com, by calling 020.7224.0017 or by submitting a formal Withdrawal of Consent form which you can request by email from clinics@zitawest.com.

Zita West Products Ltd:

Consent is required for Zita West Products Ltd to process any personal data that is not authorised by contract, and this must be explicitly given by you. Where we may ask you for personal health related data we will make it clear why and how the information will be used.

You may withdraw consent at any time by sending an email to customerservice@zitawestproducts.co.uk, by calling 01280 707401 or by submitting a formal Withdrawal of Consent form which you can request by email from  customerservice@zitawestproducts.co.uk

We use cookies. See the Cookie Notice on our website for more information.

Disclosure

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd and Zita West Products Limited (trading as “The Zita West Clinic”):

Zita West Clinics Ltd and Zita West Assisted Fertility Ltd will not pass on your personal data to any third parties without first obtaining your consent. We do not share your personal data with 3rd parties for their own marketing purposes. Any 3rd parties that we may share your data with are obliged to keep your details securely and to use them only to fulfil the service they provide you on your behalf. When they no longer need your data to fulfil this service they will dispose of the details in line with Zita West Clinic Limited’s and Zita West Assisted Fertility Ltd’s procedures. If we wish to pass your sensitive data on to a 3rd party we will only do so once we have obtained your consent.

The following third parties will receive some of your personal data for the following purpose(s) as part of our processing activities:

Lloyds – (UK)
Processing payment
Making refunds
Royal Mail (UK)
Delivering letters
CARE Fertility London (UK)
Provision of embryology and theatre services to patients of Zita West Assisted Fertility Ltd and reporting of licenced treatments provided to the HFEA
The Doctors Laboratory
Provision of tests and screens for patients of Zita West Clinics Ltd and Zita West Assisted Fertility ltd
Pharmasure Limited
Provision of prescribed drugs as part of assisted conception treatment provided by Zita West Assisted Fertility Ltd
IDEAS (UK)
Patient management system
The Human Fertilisation & Embryo Authority (HFEA)
The monitoring, recording and regulatory supervision of licenced fertility treatments
CARE Fertility Group Ltd (UK)
Clinical governance, group insurance, management and accounts
Zita West Products Ltd (UK)
Communicating marketing material on the Zita West product range
MailChimp (US) – via Zita West Clinics Ltd
Delivering marketing material relating to the Zita West Clinic and Zita West products
WP Engine (US)
Host for Zita West Clinic website
Shardex Ltd (UK)
Our web developers who help us manage our website
Our professional service providers and any 3rd party acquiring company (UK)
In the event of a business sale or merger

Zita West Products Ltd:

Zita West Products Ltd will not pass on your personal data to any third parties without first obtaining your consent. We do not share your personal data with 3rd parties for their own marketing purposes. Any 3rd parties that we may share your data with are obliged to keep your details securely and to use them only to fulfil the service they provide you on your behalf. When they no longer need your data to fulfil this service they will dispose of the details in line with Zita West Products Limited’s procedures. If we wish to pass your sensitive data on to a 3rd party we will only do so once we have obtained your consent.

The following third parties will receive some of your personal data for the following purpose(s) as part of our processing activities:

Organisation name & geographic location
SagePay – (UK)
Processing payment
Making refunds
Royal Mail (UK)
Delivering orders
TNT (UK)
Delivering orders
DHL (UK)
Delivering orders
Zita West Clinics Ltd (UK)
Communicating marketing material
MailChimp (US) – via Zita West Clinics Ltd
Delivering marketing material in relation to the Zita west product range
WP Engine (US)
Website host for Zita West Products online shop
Amazon (US)
Replies via Amazon to customer queries sent via Amazon
Shardex Ltd
Our web developers who help us manage our website and online shop
Our professional service providers and any 3rd party acquiring company
In the event of a business sale or merger

Our Transfer of Your Data Abroad

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”) and Zita West Products Ltd:

Our paper records and our internal IT systems on which we store your personal data are all within the United Kingdom.

We, or our service providers, who process your personal data for us may, however, use external IT services that are accessed from the UK but established outside the European Economic Area (EEA). In particular, services that are established in the United States of America may be used. The European Commission decides, for the purposes of Data Protection Legislation whether or not states outside of the EEA have “adequate” safeguards for personal data. The EU does not currently consider the United States as having “adequate” safeguards, although the US government operates a scheme called Privacy Shield and members of that scheme are considered to have “adequate” safeguards. We currently use MailChimp (which participates in the EU/US Privacy Shield).

When we use social networks our use (as well as your’s) is subject to each social network provider’s terms and conditions and policies, which may state that the provider will store your personal data outside the EEA. Please refer to each provider and their terms and conditions and policies.

Retention Period

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd  (trading as “The Zita West Clinic”):

Zita West Clinics Ltd and Zita West Assisted Fertility Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Zita West Cinics Limited and Zita West Assisted Fertility Ltd are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Zita West Clinics Limited and Zita West Assisted Fertility Ltd will process personal data related to your contact with the Clinic and/or your treatment. The length of time we will retain it is determined by a number of factors including the purpose for which we use that information and our obligations to regulators and under other laws.

Zita West Products Ltd

Zita West Products Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Zita West Products Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Zita West Products Ltd will process personal data related to your order history for 5 years and will store the personal data for the same period.

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”) and Zita West Products Ltd:

Your Rights as a Data Subject

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd and Zita West Products Ltd at your request, can confirm what information we hold about you and how it is processed. If Zita West Clinics Ltd, Zita West Assisted Fertility Ltd and Zita West Products Ltd does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Zita West Clinics Ltd, Zita West Assisted Fertility Ltd and Zita West Products Ltd or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (see below).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

To protect your personal data we will require proof of your identity before we are able to comply with any data request by you. We accept the following forms of ID:

A copy of your current passport or driving licence AND a utility bill/council tax bill dated within the last 3 months.

Complaints

Zita West Clinics Ltd, Zita West Assisted Fertility Ltd (trading as “The Zita West Clinic”):

The details for each of these contacts are:

  Supervisory authority contact details  GDPR Owner contact details
Contact Name: ICO (Information Commissioner’s Office) Anita O’Neill
Address line 1: Wycliffe House Zita West Clinics Ltd
Address line 2: Water Lane 37 Manchester Street
Address line 3: Wilmslow London
Address line 4: Cheshire
Address line 5: SK9 5AF W1U 7LG
Email: https://ico.org.uk/global/contact-us/ brian@zitawest.com
Telephone: 0303 123 1113 020.7224.0017

Zita West Products Ltd:

The details for each of these contacts are:

  Supervisory authority contact details  GDPR Owner contact details
Contact Name: ICO (Information Commissioner’s Office) Brian Astley
Address line 1: Wycliffe House Zita West Products Ltd
Address line 2: Water Lane Unit 3, The Sidings
Address line 3: Wilmslow Top Station Road
Address line 4: Cheshire Brackley
Address line 5: SK9 5AF NN13 7UG
Email: https://ico.org.uk/global/contact-us/ brian@zitawest.com
Telephone: 0303 123 1113 01280.707401

Special categories of personal data

Certain data are classified under the Regulation as ‘special categories’:

  • Racial
  • Ethnic origin
  • Political opinions
  • Religious beliefs
  • Philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data
  • Health data
  • Data concerning a natural person’s sex life
  • Sexual orientation
  • Other

Special categories of personal data

Certain data are classified under the Regulation as ‘special categories’:

  • Racial
  • Ethnic origin
  • Political opinions
  • Religious beliefs
  • Philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data
  • Health data
  • Data concerning a natural person’s sex life
  • Sexual orientation
  • Other