Privacy Policy

Last updated: 5 July 2026

1. Who is responsible for your data?

Human First is the data controller for the personal data collected through this website and in the course of guiding you through fertility treatment in Istanbul. If you have questions about this policy or how we handle your data, please contact us at:

• Email: info@humanfirst.nl
• Phone: +31 10 42 33 440 (phone consultation hours Mon, Thu & Fri 9:00–14:00, CET)

2. What personal data do we process?

Depending on how you interact with us, we process:

• Contact and identity data: first and last name, address, date and place of birth, phone number, email address, and — where legally required — a copy of your passport or marriage certificate.
• Special category data (health data): medical history, results of previous fertility treatments, semen analysis, bloodwork, ultrasound results and other medical information you share with us. This is "special category data" under Article 9 GDPR, subject to stricter rules.
• Insurance information: the name of your health insurer and, where applicable, reimbursement documents.
• Communication data: anything you send us via the contact form, registration form, email, phone or WhatsApp.

3. Why and on what legal basis do we process your data?

• Explicit consent (Art. 9(2)(a) GDPR) for processing and sharing your medical data with the IVF team in Istanbul — necessary to advise and guide you through treatment.
• Performance of a contract (Art. 6(1)(b) GDPR) for arranging your travel, stay, billing and other practical matters around your journey.
• Legitimate interest (Art. 6(1)(f) GDPR) for the security, functioning and improvement of our website and services.

You can withdraw previously given consent at any time by contacting us. This does not affect the lawfulness of processing carried out before the withdrawal.

4. Transferring your data to Turkey

Your treatment requires us to share relevant medical data with the IVF team at Acibadem Hospital Atasehir in Istanbul. Turkey is not a country for which the European Commission has adopted an adequacy decision, so it does not automatically offer a level of protection equivalent to the EEA.

This transfer therefore relies solely on your explicit, informed consent (Art. 49(1)(a) GDPR), because the transfer is necessary for the fertility treatment you are requesting. We never share more data than necessary for your treatment, and we agree confidentiality and security terms with the clinic wherever possible.

5. How long do we keep your data?

Type of data	Retention period
Medical data submitted by email	Up to 12 months after treatment is completed
Data submitted via WhatsApp or on paper	Destroyed within 3 months of treatment completion
Registration not followed by treatment	No later than 2 years after the last point of contact
Invoices and administrative records	7 years (statutory tax retention obligation)

After the retention period ends, your data is securely deleted or destroyed, unless a legal obligation requires longer retention.

6. Who do we share your data with?

We never sell your personal data. We only share data with:

• The IVF team at Acibadem Hospital Atasehir (Istanbul), based on your consent and only to the extent necessary for your treatment.
• Google (Google Ireland Limited), to process your submission when you fill in the contact or registration form on this website (Google Forms). See Google's privacy policy for more information.
• Your health insurer, only if and to the extent you explicitly give us permission to do so as part of a reimbursement request.

Where applicable, we enter into a data processing agreement with parties acting as processors on our behalf, in line with Article 28 GDPR.

7. Your rights

Under the GDPR, you have the following rights:

• Right to access the data we process about you
• Right to rectification of inaccurate or incomplete data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw previously given consent at any time

To exercise these rights, please send a request to info@humanfirst.nl. We respond within four weeks. To prevent misuse, we may ask you to verify your identity before fulfilling your request.

Not satisfied with how we handle your data? You have the right to lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens, or with the data protection authority in your own EU member state.

8. Minors

Our services are intended solely for adults (18 years and older). We do not knowingly collect personal data from minors.

9. Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. Every treatment recommendation is reviewed by the medical team.

10. How do we secure your data?

We take appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, unwanted disclosure and unlawful alteration. Our website is only served over a secure (https) connection.

11. Cookies

For information about cookies and similar technologies used on this website, see our cookie policy.

12. Changes to this policy

We may update this privacy policy from time to time, for example following changes in legislation or new features on our website. The most current version is always available on this page, with the date of the last update shown at the top.

13. Contact

Human First
Email: info@humanfirst.nl
Phone: +31 10 42 33 440