Privacy Policy

Privacy Policy for Customers, Clients, Patients and Known Donors

1. Introduction

At Diers Klinik ApS (“Diers Klinik”, “we”, “us” or “our”), we process personal data in connection with fertility treatment, related healthcare services, and the reservation, storage, sale and distribution of donor sperm.

This privacy policy explains how we process personal data when:

you contact us about fertility treatment, donor sperm or related services,
you receive treatment at our clinic,
you purchase, reserve or store donor sperm through us,
you purchase donor sperm from us for delivery to another fertility clinic where treatment will take place,
you participate as a known donor in a client’s/patient’s treatment pathway by prior agreement, or
you otherwise use our services as a customer/client/patient.

2. Data Controller

Diers Klinik ApS
CVR no. 33047991
Store Torv 8, 3rd floor
8000 Aarhus C
Denmark

Email: info@diersklinik.dk
Telephone: +45 20 22 85 87

If you have any questions about this privacy policy or our processing of your personal data, you are welcome to contact us.

3. Scope

This privacy policy applies to:

clients/patients receiving treatment at Diers Klinik,
customers purchasing, reserving or storing donor sperm through Diers Klinik,
customers purchasing donor sperm from Diers Klinik for delivery to another fertility clinic,
clients/customers with donor sperm in storage,
known donors participating in a specific treatment pathway by prior agreement,
partners of clients/patients where relevant to treatment, legal requirements or documentation,
potential clients/customers contacting us about treatment or the purchase of donor sperm, and
users of our website or digital services who submit information to us.

4. Types of Personal Data

Depending on the circumstances, we may process the following categories of personal data.

4.1 General personal data

We may process:

name,
CPR number or other identification number,
date of birth,
address,
email address,
telephone number,
photo ID or other identity documentation,
civil status,
occupation,
payment and invoicing information,
communication history,
appointment, enquiry, order and purchase information,
information about reservation, storage, release, shipment and delivery of donor sperm,
information about the receiving fertility clinic where donor sperm is to be delivered,
information about donor choice, donor number, donor type and relevant product details,
information about treatment outcome where relevant to medical, legal, quality, safety and traceability obligations,
information about partners of clients/patients and known donors,
website account and login information.

4.2 Special categories of personal data

As a fertility clinic, we may also process sensitive personal data, including:

health data, including medical history, medical records, diagnoses, treatment information, test results and treatment outcomes,
information relating to fertility status and reproductive health,
genetic data,
information that may indirectly reveal sexual orientation or family situation, for example through information about a partner, treatment type or known donor arrangements,
information about racial or ethnic origin,
where a known donor is involved in a treatment pathway, we may also process relevant health data, including information about reproductive health and genetic data, relating to that known donor to the extent necessary for the treatment and to comply with applicable law.

5. Collection of Personal Data

We usually collect personal data directly from you.

Where relevant, we may also receive personal data from:

a partner or known donor involved in the treatment pathway,
another fertility clinic or healthcare professional,
laboratories in connection with testing or analysis,
public authorities where required or permitted by law,
transport or logistics providers involved in the delivery of donor sperm,
our website and communication systems when you contact us or use our digital services.

6. Purposes of Processing

We process personal data for one or more of the following purposes, depending on the nature of your engagement with us:

to assess, plan, provide and follow up on fertility treatment and related healthcare services,
to communicate with you before, during and after treatment,
to create and maintain medical records and other required documentation,
to administer reservations, purchases, storage, release, shipment, delivery and distribution of donor sperm,
to coordinate with receiving fertility clinics where donor sperm purchased from us is to be used outside our own clinic,
to process direct sales of donor sperm to private individuals for treatment at another fertility clinic,
to process sales or distribution of donor sperm to external fertility clinics,
to manage treatments involving known donors,
to comply with legal requirements relating to quality, safety, documentation, vigilance and traceability in connection with the handling and use of donor sperm and other human tissues and cells,
to investigate and manage adverse events, adverse reactions, complaints and safety incidents,
to comply with legal requirements relating to reporting, pregnancy limits and traceability from donor to recipient and vice versa,
to manage payment, invoicing and accounting,
to manage website logins and customer accounts where relevant,
to protect our systems, data and business operations,
to handle enquiries, complaints, inspections, supervisory requests and other legal claims,
to prepare statistics, internal reporting and documentation, and
where permitted by law, to support scientific or quality-related follow-up work.

7. Legal Basis for Processing

The legal basis depends on the specific processing activity.

7.1 General personal data

We process general personal data on one or more of the following bases under Article 6 of the GDPR:

Article 6(1)(b), where processing is necessary in order to take steps at your request before entering into an agreement or to perform an agreement with you,
Article 6(1)(c), where processing is necessary for compliance with a legal obligation to which we are subject,
Article 6(1)(f), where processing is necessary for our legitimate interests, provided those interests are not overridden by your interests or fundamental rights and freedoms,
Article 6(1)(a), where we specifically rely on your consent.

7.2 Special categories of personal data

We process health data and other special categories of personal data on one or more of the following bases under Article 9 of the GDPR, where relevant:

Article 9(2)(a), explicit consent,
Article 9(2)(f), where necessary for the establishment, exercise or defence of legal claims,
Article 9(2)(h), where necessary for the provision of healthcare or treatment and the management of healthcare systems and services,
Article 9(2)(i), where necessary for reasons of public interest in the area of public health, including high standards of quality and safety for healthcare and human tissues and cells.

7.3 Applicable legislation

In addition to the GDPR and the Danish Data Protection Act, our processing may also be governed by applicable Danish healthcare and tissue legislation, including rules on assisted reproduction, medical record keeping, traceability, and quality and safety in relation to human tissues and cells.

8. Consent

In some situations, we may ask for your consent to process specific personal data or to collect information from third parties.

If processing is based on your consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

Please note that even if you withdraw consent, we may still be required to retain and process certain personal data where this is necessary to comply with legal obligations, including healthcare documentation, traceability, safety and medical record-keeping requirements.

9. Is It Mandatory to Provide Personal Data?

When we collect personal data directly from you, you generally provide the information voluntarily.

In many cases, however, we need certain personal data in order to:

assess whether we can offer treatment or services,
provide fertility treatment or donor sperm-related services,
complete delivery arrangements to the relevant receiving clinic,
comply with legal and regulatory requirements, and
ensure correct identification, documentation, safety and traceability.

If you do not provide the information we need, the consequence may be that we cannot offer treatment, supply donor sperm or otherwise provide the requested service.

10. Disclosure of Personal Data

We only share personal data where relevant and necessary.

Depending on the circumstances, we may disclose or make personal data available to:

public authorities and supervisory bodies, where required by law or legal obligations,
other fertility clinics or healthcare professionals involved in your treatment or in the receipt and use of donor sperm purchased from us,
laboratories involved in required testing or analysis,
transport and logistics providers involved in shipment or delivery of donor sperm,
IT, hosting, backup, website, communication and software providers acting as our data processors,
payment, bookkeeping and auditing providers where relevant,
legal advisers, insurers or other professional advisers where relevant in connection with complaints, disputes or claims,
Diers IVF, if an email has mistakenly been sent to Diers Klinik.

Where a known donor is involved in a patient’s treatment pathway, relevant information may also be shared to the extent necessary for treatment, documentation, safety, traceability and compliance with applicable law.

11. Data Processors

We use data processors who process personal data on our behalf and under our instructions.

These may include providers of:

patient record systems and other healthcare software,
secure email solutions,
cloud hosting and backup services,
website hosting and related digital infrastructure,
IT support,
laboratory or testing systems,
accounting or administrative systems.

We require our data processors to implement appropriate technical and organisational security measures and to process personal data only in accordance with our instructions and applicable law.

12. International Transfers

If, in specific cases, personal data is transferred to a country outside the EU/EEA, we will ensure that such transfer takes place in accordance with applicable data protection law and on the basis of a valid transfer mechanism.

You may contact us if you would like more information about any such transfers.

13. Retention Periods

We keep personal data for no longer than necessary, but certain information must be retained for fixed statutory periods.

13.1 Traceability and tissue-related documentation

Where personal data forms part of the documentation required to ensure full traceability in connection with donor sperm and other human tissues and cells, we retain the relevant information for the period required by applicable law.

13.2 Medical records

Where you are treated by us as a patient, we retain your medical records for the period required under applicable rules on medical record keeping.

13.3 Customers who do not proceed

If you contact us or provide information to us but do not proceed to treatment, purchase or another service, we retain your information only for as long as necessary for the relevant purpose and in accordance with applicable law and our internal retention procedures.

13.4 Complaints and legal claims

We may retain personal data for longer where necessary in connection with complaints, compensation matters, supervisory matters, disputes or legal claims.

14. Your Rights

Under data protection law, you have a number of rights in relation to our processing of your personal data.

Depending on the circumstances, these may include:

the right of access,
the right to rectification,
the right to erasure,
the right to restriction of processing,
the right to object, and
where relevant, the right to withdraw consent.

These rights are not absolute. In some situations, our legal obligations relating to healthcare documentation, traceability, safety, public health, or the establishment, exercise or defence of legal claims may mean that we cannot fully comply with a request, or that we can only comply with it to a limited extent.

If you would like to exercise your rights, please contact us using the contact details above.

15. Data Security

We take appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access.

Our security measures are designed with regard to the nature of the personal data we process, including health data and other sensitive data, and the risks associated with our activities as a fertility clinic and with the handling of donor sperm.

16. Changes to This Privacy Policy

We may update this privacy policy from time to time.

The most recent version will always be available on our website.

Where relevant, we will also inform you of significant changes in an appropriate manner.

17. Complaints

If you have questions about how we process your personal data, please contact us first. We will do our best to answer your questions.

You also have the right to lodge a complaint with the Danish Data Protection Agency.

Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark

Website: www.datatilsynet.dk

Date: Version 21.04.2026.