Privacy Policy
This privacy policy sets out how personal data is managed through this website. It is important that you read it before continuing to browse and, where applicable, before providing your personal data through the forms available on the website.
This website complies with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE), together with all other applicable data protection legislation.
This Privacy Policy may be amended in response to legislative or case-law developments or to changes in the criteria of the data protection authorities. Users are advised to consult this page periodically.
1. Identification of the data controller
For the purposes of applicable personal data protection legislation, the following details of the data controller are provided:
- Identity of the Data Controller: Innova Cryobank
- Trade name: Inicio Fertility
- Tax ID (CIF): B26570630
- Address: Colón de Larreátegui K., 47, Abando, 48011 Bilbao, Bizkaia, Spain
- Email: info@iniciofertility.com
- Domain: www.iniciofertility.com
- Activity: Reproductive Medicine Clinic
- Healthcare registration: no. 1648007365
- EU TE Code: ES020376
Hereinafter, the data controller may be referred to as Inicio Fertility.
For the purposes of the General Data Protection Regulation, the personal data provided through the forms on this website may be processed in order to manage the requests, enquiries and communications made by users and, where applicable, the corresponding clinical or commercial relationship.
Inicio Fertility implements the appropriate technical and organisational measures to ensure the security, confidentiality and integrity of personal data, in accordance with applicable legislation.
2. Principles applied to your personal data
When processing your personal data, Inicio Fertility will apply the principles established by data protection legislation:
- Principle of lawfulness, fairness and transparency: personal data will be processed lawfully, fairly and transparently, informing the user of the purposes of the processing and the corresponding legal basis.
- Principle of data minimisation: only data that is adequate, relevant and necessary for the purposes for which it is processed will be requested.
- Principle of purpose limitation: data will be collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes.
- Principle of accuracy: personal data must be accurate and, where necessary, kept up to date.
- Principle of storage limitation: data will be kept for as long as necessary to fulfil the purposes for which it was collected and for the periods required by applicable legislation.
- Principle of integrity and confidentiality: data will be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
3. How we obtain your data
The personal data processed by Inicio Fertility may come from:
- Contact form
- Appointment request form
- Newsletter subscription form, where available
- Communications made directly by Inicio Fertility
- Information provided in the context of the clinical relationship, where applicable
The user warrants that the data provided is true, accurate, complete and up to date.
4. What are your rights?
Any person has the right to obtain confirmation as to whether Inicio Fertility is processing personal data concerning them.
Data subjects may exercise the following rights, on the terms established by applicable legislation:
- Right of access: to find out what personal data we are processing.
- Right to rectification: to request the correction of inaccurate or incomplete data.
- Right to erasure: to request the deletion of their data where the legally established requirements are met.
- Right to restriction of processing: to request that the processing of their data be restricted in certain circumstances.
- Right to object: to object to certain processing of their personal data.
- Right to data portability: to receive the personal data provided in a structured, commonly used and machine-readable format, where legally applicable.
The exercise of these rights may be subject to the limitations and exceptions provided for in applicable legislation, particularly where there are legal obligations to retain certain healthcare information.
Data subjects may exercise their rights by contacting Inicio Fertility at:
Email: info@iniciofertility.com
Data subjects also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if they consider that the processing of their personal data infringes applicable legislation.
5. Purpose of the processing of personal data
When a user uses this website to make an enquiry, request an appointment or contact INICIO Fertility, they may provide certain personal data, such as their name, email address, telephone number or other information necessary to deal with their request.
Inicio Fertility will process such data solely for the corresponding purposes and in accordance with applicable legislation.
5.1. Contact form
The data provided through the contact form may be used to:
- Handle and respond to the enquiries submitted.
- Provide information about the services offered by Inicio Fertility.
- Manage requests for information.
- Maintain the communications necessary with the user in relation to their request.
5.2. Appointment request form
The data provided through the appointment request form may be used to:
- Manage the appointment request.
- Contact the user to confirm, amend or complete the information required for the appointment.
- Provide information relating to the services requested.
Where the user voluntarily provides information relating to their health or other specially protected data through the channels made available, such data will be processed solely for the corresponding purposes and with the safeguards provided for in applicable legislation.
Users are advised not to include particularly sensitive medical information in general contact forms where it is not necessary in order to deal with the request.
5.3. Newsletter subscription form
Where a newsletter subscription form is available, data such as name and email address may be requested in order to manage the subscription and send informational or promotional communications, or communications relating to the services offered by INICIO Fertility, provided that there is a valid legal basis for doing so and, where necessary, the user’s consent.
Users may unsubscribe from these communications at any time using the mechanism provided in the communications themselves.
6. Other processing purposes
Inicio Fertility may process certain personal data in order to:
- Ensure compliance with the terms of use and with applicable legislation.
- Manage and improve the operation of this website and the services offered through it.
- Maintain the security of the website and prevent fraudulent or unauthorised use.
- Manage the requests and communications made by users.
- Comply with any applicable legal obligations.
This website may also use cookies and similar technologies that allow information to be obtained about users’ browsing activity. The corresponding information is set out in the Cookie Policy.
7. Social media
Inicio Fertility may have a presence on various social media platforms.
The processing of the data of persons who follow the official profiles of Inicio Fertility will be governed by this policy and by the terms of use, privacy policies and other rules of the relevant social media platform.
Inicio Fertility may use these profiles to properly manage its presence on social media and to provide information about its activities, services, news and content.
Followers’ profiles will under no circumstances be used to send individualised advertising outside the functionalities permitted by the platform itself and by applicable legislation.
8. Disclosure and transfer of data
Inicio Fertility will not sell or rent users’ personal data.
Personal data may be disclosed to third parties where there is a legal obligation to do so, where it is necessary for the provision of certain services, where a legal basis permits it or where the user has given their consent, when such consent is required.
In certain cases, Inicio Fertility may engage service providers acting as data processors. These providers may only access the data necessary to provide the contracted services and will be subject to the corresponding confidentiality and data protection obligations.
Where international data transfers are necessary, these will be carried out in accordance with the requirements established by data protection legislation.
9. Health data and specially protected data
Owing to the nature of the activity carried out by Inicio Fertility as a reproductive medicine clinic, certain processing operations may involve the processing of health-related data, which is considered a special category of personal data under the GDPR.
This data will only be processed where there is a legal basis and, where applicable, a condition permitting the processing of special categories of data in accordance with applicable legislation.
Inicio Fertility will apply security and confidentiality measures appropriate to the particularly sensitive nature of this information.
Information relating to healthcare, medical records and assisted reproduction treatments will also be subject to the specific retention, access, confidentiality and protection obligations established by applicable healthcare legislation.
10. How long will we keep your data?
Personal data will be kept for as long as necessary to fulfil the purposes for which it was collected.
Once the corresponding relationship has ended, the data may be kept duly blocked for the periods necessary to address any potential legal liabilities or to comply with the retention obligations established by applicable legislation.
In the case of commercial communications or newsletters, data may be kept for as long as the user maintains their consent or does not request to unsubscribe, without prejudice to any legally required retention periods.
In the case of data relating to healthcare, the retention periods will be those established by applicable healthcare and data protection legislation.
11. Data security
Inicio Fertility undertakes to ensure the security and confidentiality of users’ personal data and to apply the appropriate technical and organisational measures to prevent its alteration, loss, unauthorised processing or unauthorised access.
However, no security system connected to the internet can guarantee absolute protection against all possible risks.
Inicio Fertility will ensure that persons authorised to process personal data, including employees, collaborators and suppliers where applicable, are subject to the relevant confidentiality obligations.
In the event of a personal data breach that may pose a risk to individuals’ rights and freedoms, Inicio Fertility will act in accordance with the notification and communication obligations established by applicable legislation.
12. Accuracy of the data
The user is responsible for the truthfulness, accuracy, currency and authenticity of the personal data they provide through this website.
The user undertakes to provide complete and correct information and to keep it up to date where necessary.
Inicio Fertility shall not be liable for any damages that may arise from the falsity, inaccuracy, lack of currency or incompleteness of the information provided by the user.
13. Personal data published on the website
Any personal data that may appear published on this website may not be used, reproduced or processed by third parties for purposes other than those envisaged, unless there is a legal basis permitting this or the corresponding authorisation has been obtained where necessary.
Users must at all times comply with applicable data protection and intellectual property legislation.
14. Acceptance and consent
The user declares that they have been informed of the terms relating to personal data protection and, where necessary, gives their consent to the processing of their personal data by Inicio Fertility for the purposes set out in this Privacy Policy.
Where the processing is based on a legal ground other than consent, it will be carried out in accordance with the corresponding legal basis established in applicable legislation.
Consent may be withdrawn at any time where the processing is based on such consent. The withdrawal of consent will not affect the lawfulness of processing carried out prior to that withdrawal.
15. Updates to the privacy policy
Inicio Fertility reserves the right to amend this Privacy Policy in order to adapt it to legislative, case-law or technical changes, or to changes in the services offered.
Any amendment will be published on this same page. The applicable version will be the one published at the time of consultation.
Users are advised to review this Privacy Policy periodically in order to be aware of the current version.
Last updated: August 2026.
