The Egg-splanation Podcast
Go listen
Fairtility Ltd. (“Fairtility”, “we”, “us”, “our” or the “Company”) provides In-Vitro Fertilization (“IVF”) clinics with a decision support software for embryo and oocyte quality ranking, clinic operational performance optimization and other related purposes, called CHLOE (the “Platform”). Through various tools, the Platform assists health professionals, such as embryologists or doctors, by providing insights designed to improve the efficiency and outcomes of fertility treatments (the “Services”). Fairtility also conducts fertility-related scientific research in collaboration with research partners, such as IVF clinics (“Research”).
Fairtility respects the privacy of its clients, partners, vendors, service providers, website visitors, event participants, employment candidates, Research participants, clients’ patients, Platform users and clinical staff, and is committed to protecting the personal information that is shared with us (these and any others with respect to whom we collect personal data, shall collectively be referred to as “you” or “Data Subjects”).
This policy and notice (the “Privacy Policy”) explains the types of information we collect about you, receive from you, or that you may provide to us during various interactions. These include when you or your clinic use our Services, participate in our Research activities, show interest in our Services, engage in business transactions with us, attend our conferences, or visit our website.
We are committed to being transparent about how we collect, use, maintain, and process your information. This Privacy Policy outlines our data practices to help you understand how we handle your personal data. Please read this Privacy Policy carefully to learn about our practices and how we protect your privacy.
For the purposes of the EU General Data Protection Regulation (the “GDPR”) and other applicable privacy laws, Fairtility is a data controller (“Controller”) in relation to the personal data of: the representatives of our clients and prospective clients; employees; partner and vendor representatives; website visitors; event participants; and, employment candidates. We are also Controllers of Research Data (as defined below), together with our research partners, as applicable. Finally, we are also the Controller of Patient De-identified Data (as defined below). Please note that we maintain separate privacy policies for our employees.
For the purposes of the GDPR and other applicable privacy laws, Fairtility is a data processor (“Processor”) in relation to the processing of the personal data on behalf of our clients as part of our Services. This includes client patients’ clinical data, Platform user data or other clinic staff data. When processing such data as part of the Services, we do so on behalf of the relevant client, who acts as the Controller. This processing is governed by Data Processing Agreements (DPAs) or corresponding agreements with our clients. If you are a patient, Platform user or other clinic staff member of one of our clients, please contact your clinic directly in order to receive further information regarding the processing of your personal data as part of our Services.
Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing. We also process patient data for our own business purposes, such as to train our Platform’s AI capabilities and conduct medical research.
One type of data collected is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”), as described below.
We collect Personal Data when you or your organization send it to us, or when a vendor, distributor or other business partner, sends it to us; we also collect Personal Data through our website and through our interactions with you.
We collect Personal Data required to provide Services when you register interest, or when you provide us such information in meetings, conferences and online webinars, in the course of preparing a contract, or when contacting us or submitting requests for information or support, including submitting a request for the Services’ demo, through your subscription to our newsletters, by email, or other ways in which you communicate and interact with us. This Personal Data generally includes your name (first and last), email address, phone number, job title, company name, country, the content of your inquiry, and other information you may choose to provide to Fairtility.
We also collect role-based Personal Data regarding potential customers, business partners, contractors and service providers from third parties, such as business affiliates, third party contact list vendors or publicly available sources (e.g., LinkedIn). This data may include your full name, email address, job title, company, phone number and other public business-related information.
This information is gathered to respond to your enquiries and requests, and establish and manage business relationships and communications effectively. We may also use your Personal Data to send you communications and/or direct marketing materials on our Services, products or offers we feel may be of interest to you, subject to separate consent, if required under applicable privacy law.
You do not have any legal obligation to provide any information to Fairtility. However, we require certain information in order to establish a business relationship with you, fulfill our contract with you, to take steps prior to entering into a contract with you, or to process and respond to your inquiry. If you choose not to provide us with certain information, then we may not be able to establish a business relationship with you, respond to your inquiry or provide you or your organization with some or all of the Services.
When you are using our website, we gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This includes technical information and behavioral information such as your Internet protocol (IP) address used to connect your device to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the user’s ‘clickstream’ on the websites, the period of time the user visited the websites and methods used to browse away from a page. Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which our website is used.
We likewise may place cookies or other tracking technologies on your browsing devices (see the ‘Cookies’ section below).
When you participate in our professional events, workshops, advisory professional board discussions or other professional presentations, we may record your participation in the relevant event through photographs, video recordings or other recording methods (“Event Photography Data”). Depending on the context, such data may be used for internal or promotional purposes, including in short promotional video clips, email invitations to future events, social media, website event updates, etc. This helps us achieve our aim to promote future events, by explaining the concept of our events and inspiring future participants to join them. If you do not wish to appear in such photography, you may notify us either at the events themselves or at any later point, and we will go to all reasonable efforts respect your wishes.
If you are photographed by our professional photographers at one of our photo props, we will only use your photographs in order to provide you and other event participants with access to such photographs, such as by uploading them temporarily to our/our photographers’ websites. We will not use such photographs for additional purposes without your authorization.
When you apply for a position at Fairtility, you provide us with Personal Data, such as your name, contact information, any personal information contained in your resume or CV, your response(s) to any assessment(s), background check results (subject to applicable law) and any other personal information that you decide to provide us with. Please note that though in most cases we receive this information directly from you or record such information in interview records, we may also receive information from recruitment companies, references or background check companies. This information is necessary for our recruitment and hiring purposes. If you do not provide us with this data, we will be unable to assess you as a candidate and advance your recruitment process.
We obtain pseudonymized clinical data from our Research partners (“Research Data”) as part of joint fertility-related scientific research activities.
Research Data may include, as relevant to the applicable research collaboration, any or all of the following types of Personal Data:
Research Data is transferred to us by our research partners only after removal of direct identifiers such as patient names, contact information, full dates of birth, and social identification numbers. Our research partners are responsible for the collection and secure storage of source medical records in compliance with the medical standard of care.
Research Data is used for the following purposes:
As part of providing our Services, we collect the following types of data:
Platform User Data:
This data pertains to Authorized Users of our Platform; individuals designated by our customers to use our Platform on their behalf, such as embryologists and other IVF clinic staff. Such data includes:
Platform User Data is processed for purposes which include: Platform access and account management, performance and user analytics, customer support and troubleshooting, and security and fraud prevention.
Patient Data:
This data pertains to fertility treatment patients at our customers’ clinics. Such data includes:
Pseudonymized Patient Data is processed for the following purposes:
If actively requested by our customers, we also process the following data pertaining to patients:
KPI Data:
This data pertains to the clinic staff of customers using CHLOE KPI™’s optional individual staff KPI feature. Such data includes:
Such data is aggregated and analyzed in order to generate analytical insights into clinic and staff member operations. The ultimate purpose for using such data (e.g. quality control, benchmarks, staff appraisal), is determined solely by the customer.
Summary: we process Personal Data to operate our website, meet our obligations, protect our rights, manage our business, conduct Research and improve our Services.
Please note that any Personal Data processed on our Platform on behalf of our clients as part of the Services is processed by Fairtility as a Processor. As such, Fairtility’s clients, as Controllers, determine the legal basis for the processing of such data. In this context, we use data solely to provide our Services to our clients and operate the Platform.
As Controllers, we will use Personal Data to improve our Services, operate our website, meet our contractual, ethical and legal obligations and conduct Research. All Personal Data will remain accurate, complete and relevant for the stated purposes for which it was processed, including for example:
Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:
Processing which is necessary for the purposes of the legitimate interests pursued by Fairtility or by a third party of providing an efficient and wide-ranging service to clients:
Processing which is based on your explicit consent (when required under applicable laws):
Processing which is necessary for compliance with a legal obligation to which Fairtility is subject:
Processing which is necessary for scientific health research purposes, in conjunction with our legitimate interest in conducting scientific research and promoting additional business purposes:
Summary: we share Personal Data with our service providers, partners, and group companies, and authorities where required.
We transfer Personal Data to:
Members of our Group: If in the future we have affiliates – which means affiliate companies – whether wholly or partially owned by Fairtility, and co-owned companies – we may transfer Personal Data to them.
Third Parties. We transfer Personal Data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties also include analytics and search engine providers that assist us in the improvement and optimization of our website and Platform, and promote our marketing efforts.
We periodically add and remove third party providers. At present services provided by third-party providers to whom we transfer Personal Data include primarily the following:
In addition, we may disclose your Personal Data to third parties if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case Personal Data will be one of the transferred assets. Likewise, we may transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Fairtility, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
For avoidance of doubt, Fairtility may transfer and disclose non-personal data to third parties at its own discretion.
Summary: we store your Personal Data across multiple locations globally
We store your Personal Data on servers owned or controlled by Fairtility, or processed by third parties on behalf of Fairtility, by reputable cloud-service providers.
Our customer data and Research Data are hosted in the European Union or the United States, depending on the location and choice of the customer. Such data may be accessed and processed by our headquarters in Israel (a jurisdiction deemed adequate by the EU Commission and the UK), as well as by our teams in in various locations, such as the United States and India for support and development purposes (see the following section regarding EU and UK international transfers).
Summary: we transfer Personal Data within and to the EEA, UK, USA, Israel and elsewhere, with appropriate safeguards in place.
EU and UK Personal Data is transferred to, and stored and processed at, a destination outside the European Economic Area (EEA) and UK. This includes transfer to our headquarters in Israel, a jurisdiction deemed adequate by the EU Commission and the UK, and to other countries, such as the USA and India, not currently deemed adequate. Where your Data is transferred outside of the EEA or UK, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, including entering into data protection agreements that require the recipients to adhere to data protection laws and adequate data security. Transfers from the EEA to Israel are made based on an adequacy ruling by the EU Commission. Transfers from the EEA to the USA or other non-adequate countries are made based on the Standard Contractual Clauses published by the EU Commission. Transfers from the UK to the EEA and to Israel and made based on the UK’s Adequacy Regulations. Transfers from the UK to the USA or other non-adequate countries are made based on the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses. For more information about these safeguards, please contact us as set forth below.
We transfer Personal Data to locations outside of the EEA and UK, including in particular USA and Israel, in order to:
Summary: we retain Personal Data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.
Fairtility will retain Personal Data it processes only for as long as required in our view, to provide the Services, to conduct Research and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.
Data that is no longer retained will be deleted or anonymized and used indefinitely for legitimate business purposes. Likewise, some non-personal metadata and statistical information concerning the use of our website and Services are not subject to the deletion procedures in this policy and will be retained by Fairtility. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten.
Summary: with your consent (as required under applicable laws), we place cookies and other tracking technologies on your device. You control our use of cookies through a cookie management tool on our website, or through your device and browser.
Fairtility uses cookies, pixel tags and other forms of identification and local storage (together referred to as “cookies” hereunder) to distinguish you from other users of the website and of websites of our network. This helps us to provide you with a good user-experience when you browse the website and websites of our network and also allows us to improve our website and our Services.
In many cases, these cookies lead to the use of your device’s processing or storage capabilities. Some of these cookies are set by Fairtility itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.
These cookies can fall into several categories:
Our Website uses a variety of cookies, including necessary, functional, performance, analytics and advertisement cookies.
To consult the list of cookies which we use, please click on the cookie icon on the bottom left side of our webpages, and then click on “Cookie Settings”. You may also check your browser’s settings. Instructions: https://www.wikihow.com/View-Cookies.
Third-Party Use of Your Data
Please be aware that third parties, including external social media platforms and advertising networks, may use the data collected through cookies on our website for their own advertising purposes. This means that:
Managing Your Cookie Preferences and Withdrawal of Consent
Strictly necessary cookies do not require your consent. For other cookies, however, depending on your location and applicable laws, we request your consent through our cookie banner before placing them on your device. To remove your consent to cookies you can use our website’s cookie management tool, by clicking on the cookie icon on the bottom left side of our webpages, and then clicking on “Reject all” to reject all cookies or “Cookie Settings” to remove select categories of cookies.
Likewise, you may manage your cookie preferences at any time using any of the following options:
Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.
We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. Fairtility implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, such as regarding clinical data, we encrypt data in transit and at rest. We use industry standard SSL (secure socket layer technology) encryption to transfer Personal Data. Likewise, we take industry standard steps to ensure our website and Services are safe and to prevent unauthorized access to our databases. Other security safeguards include, but are not limited to, firewalls, anti-virus, access logs, breach detection systems and physical access controls to buildings, systems and files.
Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.
Within Fairtility, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for Fairtility to fulfill its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.
Fairtility shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by Fairtility is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Fairtility shall promptly take reasonable remedial measures.
Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.
Data subjects in certain jurisdictions, such as in the EU, UK, Israel and certain US states have rights under local laws in certain circumstances and with certain exceptions, including, depending on your jurisdiction, all/some of the following rights:
For the sake of clarity, please note that:
In order to exercise any of your rights regarding data we process as a Controller, you may contact our Data Protection Officer (DPO) at privacy@fairtility.com. Note that we may have to undertake a process to identify a data subject exercising their rights. Fairtility may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or anonymized and retained in non-identifiable form. Such information may continue to be used by Fairtility at its own discretion.
In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Fairtility employees and staff, with Fairtility proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply.
We do not knowingly collect or solicit information or data from or about children under the age of 16 without parental consent, or knowingly allow children under the age of 16 to register for Fairtility Services. If you are under 16, do not register or attempt to register for any of the Services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16 without appropriate permissions, we will delete that Personal Data as soon as reasonably practicable without any liability to Fairtility. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: privacy@Fairtility.com, as soon as possible.
We may include third party links on our website. Please note that this privacy policy only applies to the Personal Data that we (or third parties on our behalf) collect from or about you and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers in order to inform websites that they do not wish to be tracked. We do not respond to or honor DNT signals.
Fairtility does not meet the threshold of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (the “CCPA”) and therefore its data processing activities as a Business (as defined in the CCPA) are not governed by the CCPA. Fairtility acts as a Service Provider (as defined in the CCPA) on behalf of its clients and, where the CCPA is applicable to its clients, Fairtility is committed to processing Personal Data (Personal Information) on their behalf in accordance with the CCPA.
The terms of this Privacy Policy will govern the use of the website, and any information collected in connection with Fairtility’s contractual obligations, Services and Research. Fairtility may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.Fairtility.com/privacy-policy. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our Services will constitute your active acceptance of the changes to and terms of the Privacy Policy.
Fairtility aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Fairtility only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.
Fairtility’s Data Protection Officer (DPO) may be contacted at: privacy@fairtility.com.
Fairtility’s appointed GDPR Article 27 EU representative, MyEDPO Ltd, may be contacted at: 3d North Point House, North Point Business Park, New Mallow Road, Cork, Ireland.
Fairtility’s appointed GDPR Article 27 UK representative, MyEDPO UK Ltd, may be contacted at: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
Fairtility’s address is: 2 Ha’shlosha St. Edgar 360, building C, entrance D, Brain Embassy, 17th floor, Office No. 5, Tel Aviv, 6706062, Israel.
Last Revised: March 6, 2025.