Privacy Policy

At Avenues, your journey to parenthood is our deepest commitment. We protect our personal and health data with the precision of our AI-driven care and the warmth of our patient-centric approach, ensuring every interaction feels as welcoming as our oak-lined clinic. This Privacy Policy explains how we collect, process, store, and safeguard your information when you visit our clinic at 2 Barnby Street, London, NW1 1AA, interact with our website @ avenues.life, engage with the Avenues App, or access our reproductive, urology, and gynaecological services across the UK and the rest of the world. We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), Care Quality Commission (CQC) standards, and Human Fertilisation and Embryology Authority (HFEA) requirements.

Information We Collect

We collect data to deliver personalised, AI-enhanced care and support your fertility journey:

Personal Data

Contact Details: Name, address, phone number, email address.

Demographic Information: Date of birth, gender, marital status, or family structure (e.g., solo parent, same-sex couple).

Billing Information: Payment details (e.g., credit/debit card), insurance information (if applicable).

Special Category Data (Health Data)

Medical History: Reproductive, urological, or gynaecological conditions, prior treatments, and medications.

Diagnostic Data: AI-driven assessments (e.g., egg, sperm, embryo, or uterine intelligence), ultrasound scans, blood tests, and lab results.

Treatment Data: Details of fertility treatments (e.g., IVF, ICSI, egg/sperm freezing), donor programs, or surgical procedures.

Lifestyle Data: Diet, stress levels, or other factors relevant to reproductive wellness.

Digital and Non-Personal Data

Website/App Usage: IP address, browser type, pages visited, and interactions with the Avenues App (e.g., appointment bookings, medication tracking).

Cookies and Analytics: Data collected via cookies (essential, analytics, or functionality) to enhance user experience and optimise our website/app. You can manage cookie preferences via our website’s consent banner, as detailed in our Cookie Policy at avenues.life/cookies.

Appointment Data: Dates, times, and locations of consultations or treatments.

How We Collect Information

We collect data:

Directly from You: Through forms, appointment bookings, the Avenues App, or communications (in-person, phone, email, or online).

During Treatment: Via consultations, diagnostics (e.g., 3D AI ultrasounds, AI sperm analysis), or embryology processes.

Automatically: Through website cookies, app analytics, or AI-driven tools like TMRW robotic cryostorage.

From Third Parties: With your consent, from referring GPs, NHS providers, insurers, or donor agencies, in compliance with UK GDPR.

How We Use Your Information

We process your data to provide exceptional care, blending cutting-edge technology with human empathy:

Provide Medical Care: Diagnose, treat, and monitor reproductive health, including IVF, egg/sperm freezing, and donor programs, with informed consent for embryo or donor data as required by HFEA.

Personalise Your Journey: Leverage AI to tailor treatment plans, predict egg/embryo viability, and optimise outcomes.

Manage Appointments: Schedule and send reminders via the Avenues App, email, or SMS, in line with PECR.

Process Payments: Handle billing, insurance claims, or treatment package fees (e.g., FAIR IVF, Impact IVF).

Communicate: Share test results, treatment updates, or reproductive wellness advice, with your consent.

Support Donor-Conceived Individuals: Provide non-identifying information to donor-conceived individuals after age 16, per HFEA regulations, with your consent.

Improve Services: Analyse anonymized data to refine AI tools, clinic processes, and patient experience, striving for excellence.

Comply with Law: Meet CQC, HFEA, NHS, or public health reporting requirements.

Research: Conduct fertility research with your explicit consent, using de-identified data.

Marketing: Send health tips or service updates (e.g., new clinics in Newcastle or Liverpool), if you opt in, per PECR.

Legal Basis for Processing

Under UK GDPR and PECR, we process data based on:

Consent: For marketing, research, or sharing sensitive data (e.g., with donor agencies).

Contract: To deliver services (e.g., FAIR IVF package, app access).

Legal Obligation: To comply with CQC, HFEA, or NHS regulations.

Legitimate Interests: For improving services or sending appointment reminders, balanced with your rights.

Vital Interests: In emergencies to protect your health.

Special category (health) data is processed with explicit consent or under health-related exemptions in the Data Protection Act 2018.

How We Share Your Information

We share data only when necessary, with robust safeguards:

Healthcare Partners: With consultants, embryologists, or labs involved in your care, with your consent.

NHS or GPs: For referrals or coordinated care, following NHS data-sharing protocols.

Third-Party Providers: With secure vendors (e.g., TMRW cryostorage, IT, billing services) under strict data protection agreements, some located in the UK, EU, US, or Israel.

Legal Requirements: To comply with court orders or public health mandates.

Donor Programs: With donor agencies or legal advisors for surrogacy/donor matching, with your consent.

We do not sell your data or share it for unrelated purposes.

Data Security

We protect your data with:

Encryption: For app, website, and cryostorage data, using SSL-certified technology.

Access Controls: Limiting staff access to a need-to-know basis.

TMRW Technology: RFID tracking and robotic cryostorage for secure egg/sperm/embryo handling, per CQC Regulation 12 (Safe Care and Treatment).

Data Protection Impact Assessments (DPIAs): Conducted for high-risk AI processing to ensure compliance with UK GDPR.

Regular Audits: To ensure CQC and UK GDPR compliance, reflecting our commitment to excellence.

User Responsibility: You are responsible for keeping your Avenues App or website password confidential and not sharing it with others.

While we strive to protect your data, transmission over the internet is not completely secure, and any data sent to our website or app is at your own risk. Once received, we apply strict security measures to prevent unauthorized access.

Third-Party Website Links

Our website or app may include links to external sites (e.g., HFEA, CQC, or partner resources). We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before sharing personal information.

Your Rights

Under UK GDPR, you have the right to:

Access: Request a copy of your data.

Rectify: Correct inaccurate data.

Erase: Request deletion of data (subject to legal retention requirements, e.g., 8 years for medical records per CQC, or 30 years for donor data per HFEA).

Restrict: Limit data processing in certain cases.

Object: Opt out of marketing or automated processing (e.g., AI profiling).

Portability: Receive your data in a transferable format.

Complain: Contact us or the Information Commissioner’s Office (ICO) at ico.org.uk.

To exercise your rights, contact our Data Protection Officer at privacy@avenues.life or 2 Barnby Street, London, NW1 1AA.

Data Retention

We retain data as required by law (e.g., medical records for 8 years under CQC, or up to 30 years for donor-related data under HFEA) or as needed for your care. Anonymized data may be kept longer for research, with your consent.

International Transfers

If data is transferred outside the UK (e.g., for international surrogacy or third-party providers in the EU, US, or Israel), we use UK GDPR-compliant safeguards, such as Standard Contractual Clauses, to ensure equivalent protection.