Baby Wiltor
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1. Data Controller Information
2. Purpose of Data Processing
With your explicit consent, which is given separately on the consent form we send you, Baby Wiltor collects, stores and processes your personal and special category (health) data. This processing is strictly necessary for the purpose of:
- Providing administrative coordination, advisory, and logistical support for your fertility journey (including IVF, egg freezing, sperm freezing, and/or surrogacy programs).
- Facilitating medical evaluations and service coordination with our partner clinics, legal representatives, and third-party service providers located outside Sweden/EU.
- Managing communication, case files, and client relationship history.
3. Categories of Personal Data Collected
We process standard personal information (such as your name, contact details, identification documents, and financial records for billing) as well as Special Categories of Personal Data (Health Data) under Article 9 of the EU General Data Protection Regulation (GDPR). This health data may include:
- Medical history, diagnostic test results, and fertility records.
- Treatment plans, genetic screening results, and medical clearances.
- Relevant personal lifestyle or background information required by partner clinics or surrogacy agencies.
4. International Data Transfers (Third Countries)
To coordinate your treatment, your health data and medical records may need to be transferred to licensed partner clinics, legal professionals, or surrogacy agencies located in countries outside the European Economic Area (EEA) (currently Mexico, Colombia, Georgia and the USA).
Data protection laws in non-EEA countries may differ from EU standards. We ensure that appropriate safeguards (such as Standard Contractual Clauses or explicit contractual obligations) are in place, or rely on your explicit consent pursuant to Article 49(1)(a) GDPR for cross-border transfers necessary to fulfill your coordination agreement.
5. Retention & Confidentiality
Your data will be stored securely using encrypted systems and access controls. We retain your personal and health records only for as long as necessary to fulfill the coordination services, comply with accounting and legal obligations, or until you exercise your right to withdraw consent (subject to legal retention requirements).
6. Your Rights under GDPR
Under the GDPR, you have the following rights regarding your personal data:
- Access & Rectification: The right to request access to or correction of your data.
- Erasure: The right to request deletion of your data ("right to be forgotten"), where legally applicable.
- Restriction & Objection: The right to restrict or object to certain processing activities.
- Data Portability: The right to receive a copy of your personal data in a structured format.
- Complaint: The right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten — IMY).