Privacy notice

TEMPLATE: Sunrise Fertility Demo Clinic has not yet reviewed this notice. It is a starting point written against the Nigeria Data Protection Act 2023, not legal advice. The clinic must check it, including the retention periods, and confirm it.

Who is responsible for your data

Sunrise Fertility Demo Clinic is the data controller for the personal data in your patient portal. That means Sunrise Fertility Demo Clinic decides why and how your data is used.

HopeFertility provides the software this portal runs on. It processes your data only on Sunrise Fertility Demo Clinic's instructions, as a data processor, and does not use it for its own purposes.

What we collect

• Your identity and contact details, such as your name, date of birth, phone number, email address and home address.
• Your health information, including fertility history, test results, scans, treatment cycles, medications and appointments. Under the Act this is sensitive personal data and is given extra protection.
• Billing and payment records.
• Records of how you use this portal, such as when you sign in, for security.

Why we use it

• To provide your fertility treatment and care.
• To coordinate your care between the doctors, nurses, embryologists and other staff treating you, and with laboratories or specialists you are referred to.
• To communicate with you about appointments, results and medications.
• To bill for treatment and keep financial records.
• To meet our legal and regulatory obligations, and to keep the portal secure.

Our lawful basis

We rely on these lawful bases under section 25 of the Act:

• Providing your treatment and care, coordinating it, communicating with you about it and billing for it: performance of our agreement to treat you.
• Keeping medical and financial records and meeting regulatory requirements: compliance with our legal obligations.
• Keeping the portal and your records secure: our legitimate interest in protecting your data, which does not override your rights.

For your health information, which is sensitive personal data, we rely on section 30 of the Act: processing for medical purposes by health professionals, and staff working under them, who owe you a duty of confidentiality. Where we want to use your data for anything else, such as research or marketing, we will ask for your explicit consent first, and you can withdraw it at any time.

Who we share it with

We share your data only with those involved in your care or who support it on our behalf, such as laboratories, specialists and our software provider, and where the law requires it. We do not sell your data.

Your portal data is stored on secure servers run for HopeFertility by its hosting providers in the European Union (Ireland), so it is transferred outside Nigeria. These transfers rely on the safeguards Part VIII of the Act requires: contracts that bind the providers to protect your data and use it only to run the service, encryption of your data while it travels and while it is stored, and access limited to the people who need it.

How long we keep it

• Medical records: at least 10 years after your last treatment with us.
• Records about eggs, sperm or embryos in storage: for as long as they are stored, and at least 10 years after storage ends.
• Billing and payment records: 6 years, for tax and accounting purposes.
• Portal sign-in and security records: up to 2 years.

Records may be kept longer where the law requires it or where they are needed for a legal claim. When data is no longer needed it is deleted or anonymised.

Your rights

Under the Act you have the right to be informed, to access your data, to have it corrected or deleted, to restrict or object to its use, to data portability, and to withdraw consent where we rely on it, without affecting what was done before. You can make a request from the Data rights page in your portal, or by contacting the clinic below.

How to complain

If you are unhappy with how your data is handled, please contact us first. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

Contact us

Sunrise Fertility Demo Clinic
1 Sunrise Close, Lekki Phase 1, Lagos, Lagos
Email: hello@sunrise-demo.hopefertility.com
Phone: +2348001000000
Data protection questions: write to our Data Protection Officer at hello@sunrise-demo.hopefertility.com.