Juniper's Privacy Notice

Hi. We’re Juniper. And we’re on a mission to make reproductive healthcare a fairer and more inclusive space.

In order to achieve our ambitions, we’ll need to collect and process some of your ‘Personal Data’ from time to time. Given the nature of Juniper’s services, this may also include ‘Sensitive Personal Data’.

This document provides you with all the information about what we collect, why, on what legal basis, who we share it with, and, most importantly, your rights.

By using the Juniper Platform (as defined within our User Terms and Conditions), you agree to the collection and use of your Personal Data in accordance with this Privacy Policy. Please take the time to review this document carefully. If you have any questions or concerns, you can contact us using the details provided below.

Please note that this Privacy Policy may be updated from time to time. Any changes will be posted on this page, and we encourage you to review it periodically to stay informed of any updates.

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So what is ‘Personal Data’?

‘Personal Data’ is considered to be any piece of information, or combination of pieces of information, which allows a living individual to be identified. We fully respect how important the right to privacy is, which is why we’ll only ever use your Personal Data in a transparent and proportionate way.

‘Sensitive Personal Data’ is, as the name suggests, data that may be particularly sensitive to you, and where we have greater obligations with respect to privacy. In the case of Juniper’s services, this is likely to concern:

Health-related data;
Genetic or biometric data;
Data concerning a person’s sexual life or orientation

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We will need an additional basis for processing such data, which we explain in more detail below.

When we refer to ‘Personal Data’ in this Privacy Notice, this includes reference to Sensitive Personal Data unless specifically stated otherwise.

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What information do we collect?

We’ll collect Personal Data from you at different stages of the user journey. This includes:

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Identity and Contact Information: When you sign up with us you’ll be asked for your first name, last name, date of birth, gender assigned at birth, role (where relevant), home address and postcodeemail address, password and mobile telephone number;
Financial Information: We may require individual bank account details in order to process payments to or from you with respect to services or offers;
Information on Services and Appointments: We’ll need to keep a record of the various appointments, referrals and services that you access through the Juniper Platform;
Website Analytics: We’ll track and store certain data when you use the Juniper Platform, including IP address, login details, and information about how you use these platforms. You can see further details under ‘Cookies’, below;
Marketing and Communications: This includes your preferences on receiving marketing from us, as well as your communication preferences.

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Cookies

No, not the sweet, delicious variety, we’re sorry to say. Cookies are small files that are created and downloaded when you visit or use the Juniper Platform or open an email.

They allow businesses to do certain things, some of which are purely technical or functional (e.g. tracking how many people visit a particular site or read a certain email) and others more marketing related (e.g. recording your preferences so the business knows which services or products to tell you about).

We here at Juniper will only ever use cookies to monitor technical and functional performance, so that we can continue to offer the best user experience. We will not use cookies for any marketing or advertising purposes.

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You are free to disable or refuse cookies at any time. This may, however, impact your use of the Juniper Platform, and certain pages may be inaccessible as a result.

If you’d like any further details on how we use cookies then please contact us using the details provided at the end of this document.

How do we use this Personal Data?

We use any Personal Data collected for a variety of reasons, but this will only ever be to the minimum extent necessary to achieve each purpose:

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Initial account set up and administration;
To provide you with all of our services and to personalise your user experience;
To enable you and our healthcare partners to communicate with one another;
This will include sharing your Personal Data with these healthcare providers in order to deliver our services. We expand on this under ‘When will we share your Personal Data?’;
To comply with our legal and regulatory obligations;
To protect our rights or the rights of others, including but not limited to fraud prevention;
To otherwise analyse and improve the services we provide to you;
For marketing and advertising purposes (unless you have ‘opted-out’ of marketing, and always within the scope of data protection laws);

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This list may not be exhaustive, but where any additional uses are outside your reasonable expectations we’ll always seek your consent first.

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What are the legal grounds on which we process your Personal Data?

Whenever a business processes your Personal Data, it must have a legal basis to do so. Sometimes, we’ll ask for your express consent to process your data, but otherwise the legal basis will usually be one of the following:

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Fulfilling our contractual obligations to you: For example, to identify and offer you appropriate services, for communications with you and healthcare service providers, to manage your account, and to make or receive payments.
Our legitimate interests and those of third parties: We will otherwise need to process your Personal Data where it’s necessary for our business, and to ensure we can play our role in ensuring employee wellbeing. However, we will always carefully balance those interests against your own, and your overriding rights and freedoms.
Provision of Health or Social Care: Specific to any Sensitive Personal Data, we will need to process such data in order to provide you with healthcare related services, in particular (but not limited to) sharing this data with healthcare professionals to ensure they are fully informed before any tests, consultations, or other appointments. We will always ensure that they are aware of and comply with confidentiality obligations.
Complying with our legal, regulatory, and audit obligations: This may involve a requirement to collect and retain your Personal Data for the purposes of our own internal compliance processes.
Consent: In certain specific cases, we may seek your specific consent to process Personal Data, but only where none of the above grounds are appropriate or relevant.

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When will we share your Personal Data?

We may sometimes share your personal information with third parties, including:

Healthcare Providers: We will need to share your Personal Data (including your Sensitive Personal Data) with any healthcare providers that may be involved in your care. This will include healthcare professionals, as well as suppliers of ancillary services and treatments (such as testing and diagnostic providers).
Other Service Providers and Business Partners: This includes other parties we work with to provide our services and to develop and maintain the Juniper Platform. We may also share Personal Data with our professional advisors, such as lawyers, accountants, auditors, and insurers, but only to the minimum extent required.
Regulators and Government / Law enforcement agencies: We may share Personal Data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party
Business Transfers: Where we sell or otherwise transfer part or all of our assets or business to a third party which then provides the services or Juniper Platform in our place.

We will always ensure that any third parties maintain appropriate safeguards to preserve and protect any Personal Data (in particular, Sensitive Personal Data) and that there is a contractual obligation on them to do so.

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Other service providers

The Juniper Platform will occasionally contain links to other websites. This privacy policy applies only to the Juniper Platform, so when you visit other websites please read their privacy policies. Juniper does not accept any responsibility for breaches or issues you may have in relation to privacy once you leave the Juniper Platform.

In particular, it is important to note that any healthcare services providers involved with your care will have their own privacy policies. It is important that you also review these prior to attending any consultations or commencing any treatments.‍

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The security and retention of your Personal Data‍

We have put in place both technical and organisational measures to ensure the security of your Personal Data at all times. This includes:

The use of encryption;
The use of data protection impact assessments;
Internal processes and training for our employees relating to data protection;
Managing third party risks, through the use of contracts and security reviews

We’ll evaluate these measures on a regular basis in order to ensure that your Personal Data remains properly protected.

We’ll keep your Personal Data for as long as we have a relationship with you. Once that relationship has come to an end, we’ll only retain your Personal Data for as long as necessary in order to:

Maintain business records for analysis and/or audit purposes;
Comply with record retention requirements under the law;
Defend or bring any existing or potential legal claims;
Deal with any complaints regarding our services

We’ll delete any Personal Data as soon as it’s no longer required for these purposes. If there’s any information we’re unable to delete entirely from our systems (e.g. for technical reasons), then we’ll put in place appropriate measures to prevent any further processing or use of the data.

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What are my rights relating to my Personal Data?

You are of course entitled to ask us to delete your account (and any Personal Data) whenever you like, only subject to:

Any outstanding payments (or other obligations) between us; and
Our legal and regulatory obligations to retain certain data (e.g. for tax purposes)

We’ll always promptly action any such request, and in any event within a maximum of 30 days.

You can also ask that we stop sending marketing communications at any time, either by adjusting your marketing preferences on the Juniper Platform, or by following the opt-out links on any marketing message we send.

You have a number of other rights under data protection laws, including to:

See/receive a full copy of any Personal Data we hold about you;
Rectify any Personal Data we hold where there are errors or omissions;
Receive your Personal Data in a portable electronic format and/or ask us to transfer it to a third party;
Where relevant, object to or ask for further details about any automated decision making (and to have any such decision reviewed by a human); and
Make a complaint - we provide further details on this below.

Please bear in mind that any request relating to your Personal Data must also be balanced against our own interests (in particular, complying with any legal and regulatory requirements) and those of any third parties.

If this prevents us from complying with a request for any reason, then we will of course tell you this and provide supporting reasons.

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Children

Due to the nature of Juniper’s business, we may collect the Personal Data of any children born following any successful treatment. This privacy policy will also apply to any child’s Personal Data we collect and process. We may ask your permission to utilise this information for the purpose of publicising any success stories.

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International Data Transfers

Your Personal Data may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will always strive as far as possible to ensure that equivalent protections are in place for the handling of your Personal Data.

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How to contact us?

Juniper Reproductive Healthcare Ltd is the ‘data controller’ for the Personal Data we collect and use. This means this is the legal entity that decides which Personal Data we collect, how we use/retain it, and who we share it with.

If you have any questions, concerns or requests on anything concerning your Personal Data, please contact us using the details below:

Email: info@getjuniper.co.uk

Post: Juniper Reproductive Health Ltd, 50 Liverpool Street, EC2M 7PY

We take these responsibilities very seriously. If you have any reason to complain we will of course investigate and respond to your complaint as a priority.

However, if you are unsatisfied with our response for any reason then you have the right to make a complaint to the UK Information Commissioner’s Office through their website https://ico.org.uk/.