GRMS Privacy Policy

1. Introduction

1.1. This Privacy Policy has been formulated to provide you with a comprehensive understanding of how GRMS (Global Society for Regenerative Medicine) records, stores, processes, transfers, and transmits your data during your visits to our website (grmsociety.com) or while utilizing the services provided therein.

1.2. In the processing of your personal data, GRMS adheres strictly to the data protection regulations outlined in the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Additionally, we adhere to guidance provided by the Information Commissioner's Office.

1.3. Personal data encompasses all information relating to you individually, including but not limited to your IP address, name, address, email data, and user behavior.

1.4. We retain the right to amend the contents of this Privacy Policy, and therefore recommend that you refer to this notice regularly.

1.5. The data controller, as defined in Article 4, Paragraph 7 of the EU General Data Protection Regulation (GDPR), is GRMS (Global Society for Regenerative Medicine). GRMS (20-22 Wenlock Road, London, England, N1 7GU) also acts as a joint controller for GRMS's personal data pertaining to stem cell donor recruitment, registration, and collection.

1.6. GRMS's data protection officer can be reached via email at dataprotection@grmsociety.com or by mail addressed to our postal address with the subject line "Data Protection Officer".

2. What types of personal data do we manage?

When you access our website or utilize the services we offer through it, we gather data pertaining to your interaction. Depending on your activities on our platform, this may encompass the following details:

2.1. Purely Informational Use:

You have the option to explore our website without furnishing any personal information. If you engage with our website solely for informational purposes, without utilizing features like making donations, registering as a stem cell donor, completing contact forms, or transmitting information to us in other ways, we do not collect personal data, except for the information automatically transmitted by your browser to facilitate your website visit. When you access our website, we collect the following necessary data to display the content and ensure its stability and security:

  • IP address
  • Time zone deviation from Greenwich Mean Time (GMT)
  • Country of access
  • Request content (specific page)
  • Request date and time
  • Referring website
  • Data transmission volume
  • HTTP status code
  • Operating system and interface
  • Browser software language and version
  • Cookie settings
  • Notification of successful access/retrieval

This information pertains to the device you use. We utilize this data (excluding your computer's IP address) solely for statistical analysis to gauge demand for our website content and services. This data is aggregated across all website users, preventing identification of individual users. It is not merged with data from other sources.

2.2. Additionally, we offer various services beyond informational content, such as donating money, requesting registration kits, and contact forms, which require you to provide further personal information.

2.2.1. Contact via Email or Contact Form: When you reach out to us via email or one of our contact forms, we process and store the information you provide (your email address and your name and phone number) to respond to your inquiries. User data might be stored in a customer relationship management system (CRM) or a similar system.

2.2.2. Donating Money via Our Website: If you choose to donate money through our website, we process the necessary data for the transaction, depending on your chosen payment method:

  • Credit card payment: We process your name, address, and email address to facilitate the transaction and send you donation confirmations if needed.
  • Direct debit payment: Your name, address, email address, and account details are processed for the payment transaction and confirmation.
  • PayPal payment: PayPal handles transactions, and we process personal data only as necessary for donation confirmation.
  • Apple Pay and Google Pay: Transactions are managed by these services, and we process personal data as required for donation confirmation.
  • Bank transfer: No additional personal data is processed beyond what is collected for informational visits to our website.
  • SMS payment: Only your phone number is processed.

2.2.3. Ordering a Stem Cell Donor Registration Kit: When ordering a registration kit to become a stem cell donor, we process the information provided during the registration process, including contact details, biological sex, height, weight, medical and GP details, ethnicity, date of birth, and genetic data from returned buccal swabs if applicable. If you become a registered donor, your data is retained in the database until your 61st birthday as a donor and then until 80 as a potential recipient unless you request removal.

2.2.4. Links to Third-Party Websites: Our website contains links to third-party provider websites. Clicking on these links redirects you to the respective third-party websites, transmitting user information in the process. We advise reviewing the data protection policies of these third-party websites before sharing any personal information. We are not responsible for their operations or data handling practices.

3. What reasons do we have for processing your personal data?

3.1. We manage your personal data with precision, ensuring it is utilized only to sustain a functional website and to deliver our content and services effectively. Processing of personal data occurs within the bounds of statutory provisions or with explicit consent from the individual concerned.

3.2. When you browse our website for informational purposes, we collect only the essential data necessary for displaying our content, ensuring site stability, and bolstering security. Our processing is grounded in the principle of "legitimate interest" as per Article 6 para. 1 (f) of the GDPR.

3.3. Communication initiated through email, or our contact form results in the utilization of your personal data solely for responding to your inquiries. Our processing, in this case, is also based on "legitimate interest" under Article 6 para. 1 (f) of the GDPR.

3.4. In instances where you contribute monetary donations through our website, your data is processed exclusively to fulfil the donation contract. This processing is justified under the legal basis of "performance of a contract" as per Article 6 para. 1 (b) of the GDPR.

3.5. Requesting a stem cell registration kit involves processing the data provided to facilitate the swift dispatch of the kit via postal service and to expedite the critical registration process. The personal and genetic data collected serves several purposes:

  • Registering you as a potential stem cell donor in both the GRMS database and to search other registries for matching purposes.
  • Facilitating the matching of your tissue characteristics with those of potential stem cell transplant recipients, specifically patients battling blood cancers or disorders in need of potentially life-saving stem cell transplants.
  • Utilizing pseudonymized genetic data for scientific analysis, assessment, and immunogenetics research aimed at enhancing the processes and outcomes of stem cell transplantation for patients with blood cancers and disorders.
  • Fulfilling lawful requests from regulatory or enforcement agencies overseeing GRMS's endeavours in stem cell donor recruitment and transplantation.

3.6. Your email address is processed exclusively to address any existing queries or provide information pertaining to the registration kit order.

3.7. The legal basis for processing your personal/genetic data lies in your express and voluntary consent, provided in accordance with Article 6 para. 1 (a) of the GDPR.

4. How is your personal data managed by us?

4.1. When utilizing our website, your data is securely transmitted to us in encrypted form, preventing unauthorized access by third parties. We store your data on highly secure servers, accessible only to authorized GRMS personnel who are thoroughly versed in pertinent Data Protection Regulations and bound to adhere to them.

5. Is personal information shared with third parties?

5.1. Your personal information may be shared with third parties under the following circumstances:

  • Donating money through the website: If you choose to use online payment services such as PayPal, Apple Pay, or Google Pay provided on our website, your information will be shared with these service providers for processing.
  • Ordering a stem cell donor registration kit: We utilize trusted third-party suppliers to process the data collected during online registration for a buccal swab pack. This is done to facilitate the processing of your request and the handling of your data and returned swabs. All third-party suppliers operate under strict data protection and confidentiality agreements to ensure the highest standards of data security, processing, and storage. Your data, in pseudonymized form, may be shared with:
    • The National Marrow Donor Program (USA),
    • The World Marrow Donor Association, and
    • Other registries for matching purposes, enabling your information to be listed on the GRMS Stem Cell Registry and made available internationally for the purpose of finding potential donors for patients in need of a stem cell transplant. Only relevant data for the donor search, such as a donor identification number, biological sex, date of birth, tissue typing results, and donor status, will be transmitted. Personal identifying information like names and addresses will not be shared.

These registries, transplant centers, and other providers are contractually obligated to use your personal data only for agreed-upon purposes and to prevent accidental disclosure to third parties. Authorized regulators and auditors may also access your data for regulatory and safeguarding purposes. If you are identified as a potential match for a patient, we will contact you again to inform you of the next steps and seek your consent for the collection of additional personal and medical information and for further processing, storage, and use of your data.

5.2. We do not sell or rent your data to any other companies or organizations. Under no circumstances will we use your email address or other data for purposes without your consent.

6. How long is your personal data retained?

6.1. General Overview: We retain any personal data you provide until the purpose for collection is fulfilled, until you withdraw consent, object to processing, or request deletion.

6.2. Website Use for Informational Purposes: For purely informational website visits, your data is stored only for the duration of your visit and is deleted upon leaving.

6.3. Contacting Us: Data from email or contact form inquiries is deleted when no longer needed, or processing is restricted according to legal requirements, assessed regularly.

6.4. Donations: Data related to donations is retained until consent withdrawal or deletion request, subject to statutory archiving periods.

6.5. Stem Cell Donor Registration: Data retention for registration kits varies based on factors like return of buccal swab and consent for additional processing.

6.6. Unreturned swabs prompt contact attempts: unresponsive cases result in data blocking and eventual deletion.

Summary of Retention Periods:

  • Potential donors: Data retained until age 61 or as per specific consent.
  • Online registrants: Data retained for 12 months post-swab dispatch.
  • Fundraising supporters: Data retained for current financial year plus six years from last donation.
  • Ineligible donors: Data retained for 12 months unless consent for alternative processing is given.

Personal Profile:

  • Ineligible donors' post-registration: Data retained for 12 months unless consent for alternative processing is given.

7. What communication will you receive from GRMS?

7.1. By joining the GRMS database of potential stem cell donors, you will receive important updates regarding the operation and regulations of stem cell donation. This includes information about the donation process, any changes to regulations, and an annual communication requesting confirmation of your current contact details and any necessary updates to your personal information.

7.2. Staying in touch with registered donors is crucial, especially considering the direct link between communication and successful donations. Since it could be years before a donor is called upon, regular contact helps reinforce their commitment and ensures they are prepared and reachable if matched with a patient in need. Timeliness is critical in stem cell donations, and maintaining contact enhances the chances of providing a life-saving opportunity.

7.3. With your consent, you may also receive promotional emails and mailings containing general information about our activities, in addition to the essential communications outlined in section 7.1.

7.4. If you wish to opt out of future communications, you can do so at any time without providing a reason. Simply send an email with the subject "STOPCOMMUNICATION" to stop@grmsociety.com or inform us through the contact details provided in the imprint.

8. What are my entitlements and rights?

You retain the following entitlements regarding the handling of your personal data:

  • Right to be informed
  • Right to rectification or erasure
  • Right to restriction of processing
  • Right to object to processing
  • Right to data portability

Should you have previously given consent for us to process your personal data, you reserve the right to withdraw it at any time. Upon withdrawal, we will cease processing your personal data. You can specify purposes, such as opting out of receiving newsletters.

To enact any of the rights, please direct your request to:

GRMS 20-22 Wenlock Road, London, N1 7GU

Alternatively, you can email us at: dataprotection@grmsociety.com

Furthermore, you possess the right to file a complaint with the Information Commissioner's Office regarding our handling of your personal data.

Right to object to processing – details as per Article 21 GDPR:

You have the right to object, at any time and for reasons concerning your specific situation, to the processing of your data based on Article 6 (1) (f) GDPR (data processing based on "legitimate interest"). Should you raise an objection, we will halt processing your personal data unless we can present compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms, or if processing is necessary to establish, exercise, or defend legal claims.

9. Storing IP addresses and cookies

9.1. Alongside the mentioned data, we utilize cookies to ensure our website's availability to you. Cookies, small text files stored on your hard drive and assigned to your browser, provide specific information to the entity setting the cookie (in this case, us). Cookies lack the capability to execute programs or transmit viruses to your computer. Their purpose is to enhance the overall user-friendliness and effectiveness of the website.

9.2 Cookies are either temporarily stored for the duration of your session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically removed after your session ends, while persistent cookies are deleted either by you, the user, or after a certain period has elapsed. Cookies can be stored either for our website (first-party cookies) or by and for third-party companies (third-party cookies), allowing for the utilization of specific services from third-party entities. Cookies serve various functions, categorized into four types:

  • Technically necessary cookies
  • Functional cookies
  • Analytical cookies
  • Advertising/tracking cookies

Technically necessary cookies are essential for the website's operation. Functional cookies streamline website usage and enhance its functionalities. Analytical cookies gather information about your usage patterns to improve the website's experience. Advertising/tracking cookies deliver interest-based advertisements.

9.3 Cookies are stored on your device and transmitted from it to us or third-party companies. As a user, you retain full control over cookie usage on your device. Adjusting the settings in your internet browser allows you to prevent cookies from being stored on your device, and you can delete already stored cookies at any time. Deactivating and/or deleting our website's cookies may limit your access to certain functions.

9.4. We utilize "local storage" and "session storage" as cookie alternatives integrated into the browser. Web storage securely stores data in the user's browser without transmitting it unencrypted over the internet.

9.4.1. Local storage: This encompasses all browser windows/tabs and is cleared solely by JavaScript or through the browser cache.

9.4.2. Session storage: This pertains to an individual browser window/tab and is automatically cleared upon closing the browser window.

10. Which social media plugins are utilized by us?

10.1. Our website incorporates social media plug-ins from various platforms. Upon accessing a specific page featuring such a plug-in, your browser establishes a direct connection with the servers of the respective social networks. This connection is initiated after you grant permission in the "privacy settings" pop-up to display external content on our site. The content of the plug-in is transmitted directly to your browser by the social networks and seamlessly integrated into the website. Your preferences regarding external content display can be managed through the "privacy settings" pop-up, accessible at any time via the "consent management" link in the website footer.

10.2. Integration of these plug-ins notifies the social networks that you have visited the corresponding page on our website. If you are logged in to any of these networks, your visit may be associated with your account. Interaction with the plug-ins, such as clicking "Like" or sharing a tweet, results in the transmission of relevant information directly from your browser to platforms like Facebook and Twitter, where it is stored.

10.3. We are not liable for the services provided by third-party platforms linked on our website, such as Twitter or Facebook. These providers cannot link IP addresses with other personal data collected through our website. Further details on data collection by third-party providers can be found on their respective websites.

10.4. Compliance with data protection legislation is the responsibility of all Staff and Volunteers of GRMS.

10.5. Staff will receive training in data protection, and use of personal data on appointment and update training annually. Volunteers will receive monthly training before engaging on activities involving data.

10.6. Staff and volunteers are responsible for ensuring that any personal data about them and supplied by them to GRMS is accurate and updated every 6 months.

10.4. Currently, we utilize social media plug-ins from Facebook, Twitter, and LinkedIn. These enable direct communication with the plug-in provider via the respective social media share buttons. Activation of a plug-in notifies the provider that you have accessed the corresponding page on our site. Data mentioned in section 2.1 of our Privacy Policy is also transmitted. For instance, Facebook anonymizes IP addresses immediately after collection in the UK. Your personal data is transmitted to and stored by the plug-in provider upon activation (for US providers, data is stored in the USA). Given that plug-in providers often collect data via cookies, we recommend clearing your browser's cookies before interacting with the plug-ins.

10.7. We lack control over data collection and processing by plug-in providers, including the full extent of data collected, processing purposes, and retention periods. We are also unaware of the procedures for deleting collected data.

10.8. Plug-in providers store collected data as usage profiles for advertising, market research, and website customization purposes. These profiles may be used to target advertising or inform other users about your activities on our website. You have the right to object to the creation of these profiles by contacting the respective plug-in provider.

10.9. Data transfer occurs irrespective of whether you have an account with the plug-in provider or are logged in. If logged in, the collected data is directly linked to your account. Regularly logging out from social networks, especially before activating the button, prevents association with your profile at the plug-in provider.

10.10 For further details on data collection and processing by plug-in providers, refer to their respective privacy policies provided below:

11. How are YouTube and other videos incorporated?

11.1. We have integrated YouTube videos into our website, sourced from GRMS's YouTube page, allowing playback directly on our site. YouTube, LLC, a subsidiary of Google Inc, operates YouTube from 901 Cherry Ave, San Bruno, CA 94066, USA, and Google's headquarters are at 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

11.2. When you visit our website and access the YouTube videos, YouTube receives information about your visit, including the data mentioned in section 2.1 of this Privacy Policy. This transmission occurs whether you have a YouTube user account and are logged in. If logged into Google, your data is linked to your account. To prevent data linkage to your YouTube profile, log out before activating the video playback. YouTube retains your data as usage profiles for advertising, market research, and website customization. This analysis, including targeted advertising, applies to all users, logged in or not. To object to data processing, contact YouTube and Google directly.

11.3. Integrating YouTube enhances our website's appeal, serving our users better. This integration is based on our legitimate interest, as per Article 6 (1) (f) GDPR.

11.4. For detailed information about YouTube's data collection and processing, refer to Google's Privacy Policy. This policy also outlines your rights and privacy settings. Please note that we lack control over YouTube and Google's data retention practices, so consult Google's Privacy Policy for specifics on personal data collection, processing, and use by these platforms.

12. Use of Google Analytics

12.1. Our website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.

12.2. We use IP anonymization, which means your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

12.3. On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be associated with any other data held by Google.

12.4. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also opt-out of being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: https://tools.google.com/dlpage/gaoptout?hl=en

12.5. We use Google Analytics to analyze and regularly improve the use of our website. With the statistics obtained, we can improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

13. Newsletter

13.1. With your consent, you can subscribe to our newsletter, which informs you about our current interesting offers and updates related to stem cell donation and GRMS activities.

13.2. To register for our newsletter, we use the double opt-in procedure. This means that after you register, we will send you an e-mail to the e-mail address specified in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and times of registration and confirmation. The purpose of the procedure is to prove your registration and, if necessary, to inform you about possible misuse of your personal data.

13.3. The only requirement for sending the newsletter is your e-mail address. The provision of additional, separately marked data is voluntary and will be used to address you personally. After your confirmation, we will store your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 Para. 1 S. 1 lit. a GDPR.

13.4. You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in every newsletter e-mail, or by sending an email to unsubscribe@grmsociety.com.

14. Changes to Our Privacy Policy

We may update this privacy policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy.

15. How to Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

  • By email: dataprotection@grmsociety.com
  • By mail: Data Protection Officer, GRMS, 20-22 Wenlock Road, London, England, N1 7GU

If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.