Privacy Policy

Privacy Policy – Cryo Medical Logistics Ltd

Effective date: 11 November 2026

 

This Privacy Policy explains how Cryo Medical Logistics Ltd ("CML", "we", "us", "our") collects, uses, shares and protects personal information. It applies to visitors to our website, clients, clinics, laboratories, partner organisations, job applicants and anyone who uses or interacts with our cryogenic and medical logistics services.

 

We process personal data in line with:

 

- the UK General Data Protection Regulation (UK GDPR)

- the Data Protection Act 2018

- the Privacy and Electronic Communications Regulations 2003 (PECR)

- the Data (Use and Access) Act 2025, which amends the laws above

- the EU General Data Protection Regulation (EU GDPR), where it applies to clients or other individuals in the European Union

 

1. Who We Are

 

Cryo Medical Logistics Ltd is the data controller for the personal data described in this policy.

 

Company number:15874405

Registered address: The Wenta Business Centre, Innova Park, Electric Avenue, Enfield EN3 7XU, London, United Kingdom

General enquiries: transports@cryomedicallogistics.com | +44 20 8150 0059

 

2. Personal Data We Collect

 

We collect personal data only when we need it to provide our services, meet our legal obligations or pursue our legitimate interests, or when you have given your consent.

 

2.1 Information you give us

 

You may give us personal information when you:

 

- request a quote or book a transport

- sign our Services and Transport Consent Agreement

- fill out our contact form or communicate with our team by email, phone or messaging apps

- subscribe to newsletters or request educational materials

- apply for an employment or contractor role

 

This may include:

 

- full name, date of birth and signature

- home, postal or collection address

- email address and phone number

- a copy of your passport or other official photo ID

- job title and company or clinic details (for business contacts)

- payment and billing details

- details of the biological material to be transported, and the sending and receiving clinics

- documents needed for the shipment, such as consents, permits and customs paperwork

- details of your enquiry and our communications with you

- CV and employment information (if you apply to work with us)

 

2.2 Special category (health) data

 

Some of the information we handle is health data, which the law treats as special category data. This may include:

 

- information about IVF or fertility treatment, including treatment cycles

- information about gametes, embryos or other cryogenic samples

- infectious disease status (for example, HIV or hepatitis status) that you disclose to us

- sample identifiers, and patient or donor ID numbers provided for the shipment

 

We process health data only when we need to, and on the following legal bases:

 

- your explicit consent (UK GDPR Article 9(2)(a)), which you give in our Consent Agreement

- the establishment, exercise or defence of legal claims (Article 9(2)(f))

 

2.3 Information we receive from others

 

We also receive personal data about you from:

 

- the clinics, laboratories and cryostorage facilities sending or receiving your material

- surrogacy agencies, travel agents or other parties who contact us on your behalf

- customs, airline and regulatory bodies involved in your shipment

- payment providers, about the status of your payments

 

2.4 Information collected automatically

 

When you use our website, we may collect:

 

- IP address, browser type and device information

- pages visited and time spent on the site

- cookie and analytics data (see section 11)

 

2.5 If you don't provide your data

 

We need certain information to carry out a transport, such as your identity, photo ID, the details of the clinics involved and the information needed for permits and customs. If you don't provide it, we may not be able to provide our services.

 

3. Why We Use Your Data, and Our Legal Basis

 

Contract (UK GDPR Article 6(1)(b)). We use your data to:

- prepare quotes and enter into an agreement with you

- coordinate and carry out your transport

- communicate with you about schedules, documents and payments

 

Legal obligation (Article 6(1)(c)). We use your data to:

- meet customs, border and regulatory requirements

- meet financial, audit and tax obligations

- respond to court orders or lawful requests from authorities

 

Legitimate interests (Article 6(1)(f)). We use your data, balanced against your rights, to:

- run, secure and improve our website and services

- prevent fraud and protect our business

- train our staff

- keep records needed to resolve disputes and defend legal claims

We carry out a Legitimate Interests Assessment where required.

 

Consent (Article 6(1)(a)). We use your data, with your consent, to:

- send newsletters and marketing (see section 4)

- process your health data (see section 2.2)

- handle optional form submissions

 

Withdrawing consent. You can withdraw your consent at any time by contacting us. Withdrawing consent does not affect processing we have already carried out. If you withdraw consent for us to use your health data during a booking, we may not be able to continue the transport. We will still keep the records we need for legal, regulatory and accounting purposes, or to establish or defend legal claims.

 

We do not sell your personal data. We do not make decisions about you based solely on automated processing.

 

4. Marketing

 

We will send you marketing emails only if you have agreed to receive them, or if you are an existing client and we are telling you about similar services. Every marketing email includes a way to unsubscribe. We never allow third parties to use your information for their own marketing.

 

5. Who We Share Your Data With

 

We share personal data only when we need to, and only as much as is needed. Depending on your shipment, we may share it with:

 

- the clinics, laboratories, cryostorage facilities and medical professionals involved in your shipment

- our couriers, Personal Escorts, subcontractors and partner logistics providers

- airlines, airports, and customs, border and regulatory authorities

- our insurers, legal advisers, auditors and accreditation bodies

- our IT, hosting, email, messaging, e-signature, accounting and payment providers

 

Where a third party processes data on our behalf, such as our IT or software providers, we put a written data processing agreement in place and require appropriate security measures. Public authorities, airlines and clinics act under their own legal obligations and their own privacy policies.

 

6. International Transfers

 

Because we move biological material between countries, we need to share your data with clinics, couriers, airlines and authorities outside the UK, including in countries whose data protection laws differ from the UK's.

 

When we transfer personal data outside the UK, we rely on one or more of the following:

 

- UK adequacy regulations, for countries the UK recognises as having adequate protection

- the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses

- the transfer being necessary to perform the contract you have asked us to carry out, for example sending your details to your receiving clinic abroad

- your explicit consent, where appropriate

 

You can contact us for more information about the safeguards we use.

 

7. How We Protect Your Data

 

We use physical, technical and organisational measures to protect your data, including but not limited to:

 

- access restricted to staff who need it for their role

- secure handling and storage of documents

- confidentiality obligations for all staff, couriers and contractors

 

No system is completely risk-free, but we take all reasonable steps to keep your information safe. If a data breach is likely to result in a high risk to you, we will tell you without undue delay.

 

8. How Long We Keep Your Data

 

We keep personal data only for as long as we need it. Our retention periods are:

 

- Health data: for the duration of the service, then only as long as needed for the records above

- Passport and photo ID copies: [12 months] after the transport is completed, unless needed for a dispute or legal claim

- Invoices and financial records: 6 years from the end of the financial year they relate to

- General enquiries that don't lead to a booking: [2 years] after our last contact

- Marketing consent records: until you withdraw consent, plus a record that you did so

- CVs and application information: 12 months, unless you join us

 

Backups are deleted on a rolling schedule.

 

9. Your Rights

 

You have the right to:

 

- access the personal data we hold about you

- have inaccurate data corrected

- have your data erased, where we have no legal reason to keep it

- restrict how we use your data

- object to how we use your data, including for direct marketing

- receive your data in a portable format

- withdraw your consent at any time

- not be subject to decisions based solely on automated processing

 

To exercise any of these rights, contact our privacy contact (section 1). We may need to verify your identity. We will respond within one month. For complex requests, we may extend this by up to two further months, and we will tell you if we do.

 

10. Complaints

 

If you are unhappy with how we have handled your personal data, please complain to us first:

 

- Email: contact@cryomedicallogistics.com, with "Data protection complaint" in the subject line

- Post: Privacy Contact, Cryo Medical Logistics Ltd, The Wenta Business Centre, Innova Park, Electric Avenue, Enfield EN3 7XU, London, United Kingdom

 

We will acknowledge your complaint within 30 days, investigate it, keep you informed of progress and tell you the outcome without undue delay.

 

If you are not satisfied with our response, you can complain to the Information Commissioner's Office (ICO):

Website: www.ico.org.uk

Helpline: 0303 123 1113

 

11. Cookies

 

Our website uses cookies and similar technologies.

 

- Essential cookies are needed for the website to work, for example for security and navigation. These do not require your consent.

- Analytics and functionality cookies help us understand how the site is used and improve it. Where the law allows these without consent, we will tell you about them and give you a simple way to opt out.

- Any other cookies, such as advertising or tracking cookies, are only set with your consent, which you can give or refuse through our cookie banner.

 

You can change your cookie choices at any time by adjusting your browser settings.

 

12. Children

 

Our services are not directed at anyone under 18, and we do not knowingly collect personal data directly from children.

 

13. External Links

 

Our website may link to other websites. We are not responsible for their privacy practices, and we recommend reading their privacy policies before giving them any information.

 

14. Changes to This Policy

 

We may update this Privacy Policy to reflect changes in the law, our services or best practice. We will publish all updates on our website, and the effective date at the top will show when it was last changed. If we make significant changes, we will tell existing clients directly.

 

15. Contact Us

 

Cryo Medical Logistics Ltd

The Wenta Business Centre, Innova Park, Electric Avenue, Enfield EN3 7XU, London, United Kingdom

Email: transports@cryomedicallogistics.com

Phone: +44 20 8150 0059