Privacy Policy
Last updated: [DATE]
1. Who we are
Alba Longevity is the trading name of [FULL LEGAL NAME AND LEGAL STRUCTURE], at [BUSINESS ADDRESS]. We are the controller responsible for personal information used to operate our website, respond to enquiries and provide Alba’s coordination service.
Contact us about privacy at [PRIVACY EMAIL ADDRESS] or by post at the address above. [ADD REPRESENTATIVE OR DATA PROTECTION OFFICER DETAILS IF APPLICABLE.]
This policy covers www.alba-longevity.com and Alba’s enquiry and client administration. It does not replace the privacy policies of independent clinics, laboratories or other providers.
2. Information we collect
We collect information you provide when you enquire, request a guide, communicate with us, subscribe to updates or engage our service. This may include your name, email address, telephone number, country of residence, service interests, preferred location, appointment arrangements and correspondence.
If you become a client, we may also keep the administrative details needed to coordinate services, record agreed fees and manage invoices or complaints. We do not need a complete clinical record to provide introductions.
Our website may collect technical information such as IP address, browser type, device information and pages visited. Optional tracking depends on your choices and the technology described in our cookie information.
We may receive necessary administrative information from a provider involved in your requested service, such as confirmation of appointments or referral status. We will explain the source and use of information where required.
Actual systems and providers used by Alba: [LIST WEBSITE/FORMS, EMAIL, CRM, PAYMENT, MESSAGING, ANALYTICS AND MARKETING PROVIDERS THAT ARE ACTUALLY USED; WIX IS THE WEBSITE PLATFORM].
3. Why we use information and our lawful bases
Enquiries and requested guides: we use your details to respond and provide the information you ask for. Where this concerns a potential service agreement, we rely on steps taken at your request before entering a contract. For other enquiries, we rely on our legitimate interest in responding to people who contact us.
Client coordination: we use necessary administrative details to perform our service agreement, arrange introductions and communicate about appointments.
Business administration: we rely on legal obligations for required financial records and disclosures. We rely on legitimate interests for proportionate record keeping, resolving complaints, protecting our systems and establishing or defending legal claims. We consider your rights and expectations when relying on legitimate interests.
Marketing updates: we use consent for optional newsletters and promotional emails to individuals. Requesting a guide or making an enquiry does not automatically subscribe you to unrelated marketing.
Optional website tracking: we obtain consent where required for the relevant cookies or similar technologies. The cookie information explains the technologies and applicable choices.
4. Health information
Please do not submit medical records, test results or detailed health information through the general enquiry form. Your treating provider should collect clinical records through its own appropriate process.
If Alba needs specific health information for a task you request, we will explain the information needed, its purpose, the recipients and a suitable way to provide it. Under the consent-based arrangement described here, we obtain your explicit consent before intentionally using that information. We use consent as the Article 6 lawful basis and explicit consent as the Article 9 condition for that task.
You can withdraw that consent by contacting [PRIVACY EMAIL]. Withdrawal does not affect earlier lawful processing. It may prevent us from continuing the particular task that requires the information.
If you send health information unexpectedly, we will restrict access and assess whether it is necessary and whether there is a lawful basis to retain or use it. Where it is unnecessary, we will arrange its deletion. Sending unsolicited health information does not by itself establish explicit consent for wider use or sharing.
Where information must be retained for legal claims or another legal requirement, we will identify the relevant lawful basis and special-category condition rather than assume consent covers it.
5. Sharing information
We share necessary contact and administrative details with the provider relevant to your requested introduction or service. We explain the proposed recipient before making the introduction. A general enquiry does not authorise circulation of your details throughout our network.
Our clinical network may include providers in Switzerland, Germany, the UAE and Turkey. The actual recipient depends on the service you request. Where necessary, we separately explain and obtain explicit consent for health information sharing under the arrangement above.
We also use service providers to operate our website, communications and administration. They receive only the information needed for their role, under appropriate arrangements. We may disclose information to professional advisers, regulators or public authorities where necessary and lawful.
We do not sell personal information. Referral payments do not require access to a full medical record; we seek to keep commission administration limited to necessary referral and transaction information.
Where a clinic determines how clinical information is used, it acts as an independent controller and provides its own privacy notice. If an arrangement involves shared decisions about processing, we will explain the parties’ responsibilities separately.
6. International information transfers
Some providers and systems may handle information outside the UK. An international introduction may also require sharing information with a provider in your chosen country.
Actual transfers and protections: [IDENTIFY DESTINATION COUNTRIES, RECIPIENTS AND APPLICABLE UK ADEQUACY REGULATIONS OR CONTRACTUAL SAFEGUARDS, SUCH AS THE UK IDTA OR ADDENDUM, WITH ANY REQUIRED ASSESSMENT. IDENTIFY ANY VALID EXCEPTION USED FOR A SPECIFIC TRANSFER. DO NOT PUBLISH THIS SECTION UNTIL THE ARRANGEMENTS ARE VERIFIED.]
We will not assume that requesting an overseas introduction removes the need for a lawful transfer arrangement. You can ask [PRIVACY EMAIL] for details of the relevant safeguards and how to obtain a copy.
7. AI-supported clinical monitoring
Clinical providers may use AI-supported tools to combine assessment data and support progress monitoring. The provider is responsible for explaining its tools, the information used, the organisations involved and the clinical review process.
Alba’s role in accessing or handling data from those tools is: [CONFIRM WHETHER ALBA RECEIVES NO DATA, ADMINISTRATIVE STATUS ONLY, OR OTHER INFORMATION; IDENTIFY THE PROVIDER AND RELEVANT NOTICE].
Alba’s own use of automated decisions or profiling is: [CONFIRM WHETHER ANY IS USED. IF NONE, STATE: “Alba does not make decisions with legal or similarly significant effects on you solely through automated processing.”]
If our use changes, we will explain it and meet the applicable requirements before introducing the new processing. Clinical AI tools are not covered simply by agreeing to Alba’s general terms.
8. Marketing choices
You can unsubscribe using the link in a marketing email or by contacting [PRIVACY EMAIL]. You can withdraw marketing consent at any time. We may retain minimal suppression information so we can respect your choice.
Service communications about an enquiry or agreed service are separate from promotional updates.
9. Cookies and similar technologies
Our website uses [CONFIRM ACTUAL ESSENTIAL COOKIES AND OPTIONAL ANALYTICS/MARKETING TOOLS]. Our cookie information and preference controls describe their purposes, providers and duration.
Where consent is required, optional technologies will not run until you agree. You can change your choices through [COOKIE SETTINGS LINK OR INSTRUCTIONS]. Declining optional cookies does not prevent a general enquiry.
10. How long we keep information
We keep information only for as long as necessary for the relevant purpose, taking account of legal record-keeping requirements, complaints and claims. Our retention schedule is:
Enquiries that do not become clients: [PERIOD AND STARTING POINT].
Client administration and correspondence: [PERIOD AND STARTING POINT].
Invoices and accounting records: [APPLICABLE PERIOD].
Health information exceptionally held by Alba: [SHORT, PURPOSE-SPECIFIC PERIOD AND DELETION PROCESS].
Marketing records and suppression entries: [PERIOD OR CRITERIA].
Website logs and optional analytics: [PERIODS].
When information is no longer needed, we delete it or make it anonymous. Clinical providers apply their own retention schedules to medical records.
11. Security
We use appropriate technical and organisational measures for the information we handle, including controlled access and suitable arrangements with service providers. We cannot guarantee absolute security of every transmission or system.
Please use the designated process for sensitive information rather than ordinary enquiry forms. Contact us promptly if you believe information has reached the wrong recipient.
12. Your rights
Depending on the circumstances and applicable law, you may ask to access your personal information, correct it, erase it, restrict its use or receive certain information in a portable form. You can withdraw consent where we rely on it.
You have the right to object to processing based on legitimate interests. You also have the right to object to direct marketing at any time.
Contact [PRIVACY EMAIL] to exercise your rights. We may need proportionate information to verify your identity. We respond within the applicable legal timeframe and explain any lawful exception or extension.
If a clinic holds the relevant records independently, requests concerning those records should be directed to that clinic. We can help identify the appropriate contact.
13. Providing information
You do not have to subscribe to marketing or provide medical records to make a general enquiry. We need enough contact information to reply and sufficient administrative information to provide an agreed service. If you do not provide information necessary for a specific task, we may be unable to complete it and will explain why.
14. Complaints and updates
Contact [PRIVACY EMAIL] if you have concerns about Alba’s use of your information. You can also complain to the UK Information Commissioner’s Office at ico.org.uk or call 0303 123 1113. Where applicable, you can contact the data protection authority in your country.
We review this policy when our practices change. The date above identifies the latest version. We bring significant changes to your attention where required.