Privacy Policy

1. Introduction

Concipio Fertility Ltd ("Concipio", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our fertility tracking application and website at concipiofertility.com (together, the "Service").

This policy is written in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We act as the data controller for the personal information you provide to us through the Service.

Please read this Privacy Policy carefully. By using our Service, you acknowledge that you have read and understood this policy.

2. Who We Are

The data controller responsible for your personal information is:

If you have any questions about how we handle your personal information, or wish to exercise any of your rights, please contact us using the details above.

3. Information We Collect

We collect the following categories of personal information:

3.1 Account and Registration Information

• Name and email address
• Date of birth (to verify eligibility and personalise cycle tracking)
• Password (stored in encrypted form)
• Account preferences and notification settings

3.2 Health and Fertility Data (Special Category Data)

As a fertility tracking service, we collect data that constitutes special category data under UK GDPR, including:

• Menstrual cycle data (cycle length, period dates, flow information)
• Ovulation and fertility window predictions
• Symptoms and physical signs you choose to log (e.g. cervical mucus, basal body temperature)
• Mood and wellbeing data you choose to record
• Pregnancy status or conception-related goals you share with us
• Any other health information you voluntarily enter into the app

We only process this special category data with your explicit consent, which you provide when you create an account and use these features. You may withdraw your consent at any time (see Section 11).

3.3 Usage and Activity Data

• Pages visited and features used within the Service
• Frequency and duration of your sessions
• In-app interactions and preferences
• Search queries within the Service

3.4 Technical and Device Data

• IP address and approximate location (country/region)
• Device type, operating system, and browser type
• Unique device identifiers
• Time zone and language settings

3.5 Communications

• Email correspondence with our support team
• Survey responses and feedback you provide
• Marketing preferences and opt-in/opt-out records

4. How We Use Your Information

We use your personal information for the following purposes:

• Providing the Service: Delivering our fertility tracking features, personalising your experience, and maintaining your account
• Cycle and fertility analysis: Processing your health data to generate cycle predictions, fertility windows, and insights
• Service communications: Sending you account-related notifications, service updates, and security alerts
• Customer support: Responding to your queries and resolving issues
• Service improvement: Analysing usage patterns (using anonymised or aggregated data where possible) to improve our features and user experience
• Safety and security: Detecting and preventing fraud, unauthorised access, and other unlawful activity
• Legal compliance: Meeting our legal and regulatory obligations under UK and EU law
• Marketing (with your consent): Sending you relevant content, offers, and updates — only where you have opted in

5. Legal Bases for Processing

Under UK GDPR, we must have a lawful basis to process your personal information. We rely on the following legal bases:

• Contract performance (Article 6(1)(b)): Processing necessary to provide you with the Service under our Terms of Service — for example, creating and managing your account.
• Explicit consent (Article 6(1)(a) and Article 9(2)(a)): For processing your special category health and fertility data, and for sending you marketing communications. You can withdraw consent at any time without affecting the lawfulness of prior processing.
• Legitimate interests (Article 6(1)(f)): For purposes such as fraud prevention, improving our Service, and ensuring the security of our systems — where these interests are not overridden by your rights.
• Legal obligation (Article 6(1)(c)): Where we are required to process data to comply with UK law, such as tax and regulatory requirements.

6. Special Category (Health) Data

Fertility and health data is classified as special category data under UK GDPR, which carries enhanced protections. We take the following additional measures when handling your health data:

• We only collect health data that is necessary to provide the fertility tracking features you request
• We process it only with your explicit consent, clearly obtained at the point of collection
• Access to health data is strictly limited to authorised personnel on a need-to-know basis
• Health data is encrypted both in transit and at rest
• We do not sell or commercially exploit your health data in any form
• We do not share your individual health data with third parties for their own marketing purposes

7. Cookies and Tracking Technologies

We use cookies and similar technologies (such as web beacons and pixel tags) on our website. These help us operate and improve the Service. The categories of cookies we use are:

• Strictly necessary cookies: Essential for the website to function and cannot be switched off. They are usually only set in response to actions you take, such as logging in or setting your privacy preferences.
• Performance and analytics cookies: These help us understand how visitors interact with our website by collecting and reporting information anonymously. We use these to improve our Service.
• Functional cookies: These allow the website to remember choices you make (such as language preferences) and provide enhanced features.
• Marketing cookies (only with your consent): Used to track visitors across websites and display relevant advertising. These are only set with your explicit consent.

When you first visit our website, we will ask for your consent before placing non-essential cookies. You can manage or withdraw your cookie preferences at any time via our cookie settings or through your browser settings. Please note that disabling certain cookies may affect the functionality of the Service.

8. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

• Service providers: We work with carefully selected third-party companies that help us operate the Service (e.g., cloud hosting, analytics, email delivery). These providers act as data processors and are contractually required to process data only on our instructions and in compliance with UK GDPR.
• Legal requirements: We may disclose your information if required to do so by law, court order, or regulatory authority, or if we reasonably believe disclosure is necessary to protect the rights, property, or safety of Concipio, our users, or others.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of our business, your personal information may be transferred to the new entity. We will notify you and provide options before any such transfer.
• With your consent: We will share your information with third parties in any other way only with your explicit prior consent.

We will never share your individual health or fertility data with insurers, employers, or advertising networks.

9. International Data Transfers

Some of our service providers may be located outside the UK. Where we transfer your personal data outside the UK, we ensure that appropriate safeguards are in place to protect your information, such as:

• Transfers to countries with an adequacy decision under UK GDPR
• Use of UK International Data Transfer Agreements (IDTAs) or other approved transfer mechanisms
• Appropriate contractual clauses and supplementary measures

You can obtain further details about our international transfers by contacting us at privacy@concipiofertility.com.

10. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfil the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account data: Retained for the duration of your account, plus up to 3 years after closure to resolve disputes or comply with legal obligations
• Health and fertility data: Retained for the duration of your account. Upon account deletion, health data is deleted within 30 days unless you request immediate deletion
• Usage and analytics data: Typically retained in anonymised form for up to 2 years
• Communications: Support emails retained for up to 3 years
• Financial and transaction records: Retained for 7 years in accordance with UK tax law requirements

When personal information is no longer needed, we securely delete or anonymise it.

11. Your Rights Under UK GDPR

As a UK resident, you have the following rights in relation to your personal information:

• Right of access: You have the right to request a copy of the personal information we hold about you (a "Subject Access Request").
• Right to rectification: You can ask us to correct inaccurate or incomplete personal information we hold about you.
• Right to erasure ("right to be forgotten"): You can ask us to delete your personal information in certain circumstances, such as when it is no longer needed for the purpose it was collected.
• Right to restrict processing: You can ask us to pause or limit how we use your personal information in certain circumstances.
• Right to data portability: Where processing is based on your consent or contract, you can ask us to provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You can object to processing based on our legitimate interests. You also have an absolute right to object to direct marketing at any time.
• Rights related to automated decision-making: You have the right not to be subject to decisions made solely by automated processing that have a significant effect on you.
• Right to withdraw consent: Where we process your data based on consent (including for health data and marketing), you can withdraw your consent at any time. This does not affect the lawfulness of processing before the withdrawal.

To exercise any of these rights, please contact us at privacy@concipiofertility.com. We will respond to your request within one month. We may ask you to verify your identity before acting on certain requests.

There is no charge for exercising your rights in most circumstances, though we may charge a reasonable fee or decline a request if it is manifestly unfounded or excessive.

12. Data Security

We implement appropriate technical and organisational security measures to protect your personal information from unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Access controls and authentication requirements for staff
• Regular security assessments and penetration testing
• Staff training on data protection and security
• Incident response procedures

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware, and will notify you directly where required by law.

13. Children's Privacy

The Service is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from persons under 18. If we become aware that we have inadvertently collected personal data from a child under 18 without appropriate consent, we will take steps to delete that information as promptly as possible.

If you believe we may have collected information from a child under 18, please contact us immediately at privacy@concipiofertility.com.

14. Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to read the privacy policies of any website you visit. This Privacy Policy applies only to information collected by Concipio Fertility Ltd.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by email or by a prominent notice on our website before the changes come into effect.

We encourage you to review this Privacy Policy periodically. The "Last updated" date at the top of this page indicates when the policy was last revised. Your continued use of the Service after any changes constitutes your acknowledgment of the updated policy.

16. How to Complain

If you have any concerns about how we handle your personal information, we encourage you to contact us first so we can try to resolve the issue:

Email: privacy@concipiofertility.com

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent data protection authority:

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please do contact us in the first instance.

17. Contact Us

For any questions, requests, or concerns about this Privacy Policy or our data practices, please contact us at: