Privacy Policy
Effective Date: October 2, 2025
Last Updated: November 13, 2025
STATUS: DRAFT (Not Live) v1.2
1. Who We Are
SAENA Ltd (“we,” “us,” or “our”) is a private limited company registered in England and Wales under company number 16734938, with its registered office at 20 Wenlock Road, London, England, N1 7GU United Kingdom. We operate www.ikivana.com (the “Site”), providing lead generation and marketing services to connect UK users with international fertility and wellness providers via IKIVANA Wellness LLP (under registration). We are the data controller for personal data processed via the Site.
You can contact us at:
Email: <contact@ikivana.com>
Address: DPO/GDPR, 20 Wenlock Road, London, England, N1 7GU United Kingdom
For data protection queries, contact our Data Protection Officer (DPO) at the above details. We are registered with the ICO under reference ZC039535 (Link: https://ico.org.uk/ESDWebPages/Entry/ZC039535).
This privacy policy explains how we collect, use, and protect your personal data when you use the Site. It complies with UK GDPR and applies to all visitors and users.
2. Personal Data We Collect
We collect minimal personal data directly from you for lead generation purposes only. This includes:
Basic contact details: Name, email address, and phone number (if provided).
We do not collect sensitive personal data, such as health information (e.g., medical history or fertility details). If you inadvertently provide such data, we will delete it immediately and notify you. No automated decision-making or profiling occurs.
3. How We Collect Your Personal Data
We obtain your data directly when you:
Submit a lead generation form on the Site to request a ‘Fertility Connect Call’.
Submit a ‘Ask a Question’ form on the site on the ‘Contact Us’ page.
If you email us directly on <contact@ikivana.com>
We do not collect data from third parties or automated tracking beyond essential cookies (see our Cookie Policy).
4. How We Use Your Personal Data and Our Legal Basis
We use your data solely to:
Facilitate lead generation by transferring your details to IKIVANA Wellness LLP for scheduling informational Fertility Connect Calls (general discussions on fertility topics, not medical advice).
Send you confirmation emails about your request.
Comply with legal obligations (e.g., record-keeping).
Our lawful basis for processing is explicit consent (Article 6(1)(a) UK GDPR), obtained via a clear opt-in checkbox on forms (e.g., “I consent to my data being used for lead generation and shared with IKIVANA Wellness LLP”). You can withdraw consent at any time (see Section 8). We do not rely just based on legitimate interests and consent ensures transparency in this sensitive context.
Processing is necessary and proportionate for our services but does not involve providing any GMC-regulated medical advice or HFEA-licensed activities.
5. Sharing Your Personal Data
We share your data only with:
IKIVANA Wellness LLP (our affiliate in India) to arrange Fertility Connect Calls. This is limited to basic contact details.
We do not sell your data or share it with third parties for marketing. All recipients are bound by data processing agreements ensuring UK GDPR-equivalent protections.
6. International Data Transfers
Your data may be transferred to IKIVANA Wellness LLP in India (outside the UK/EEA, a non-adequate country). We safeguard transfers using:
Standard Contractual Clauses (SCCs) approved by the ICO, supplemented by a Transfer Risk Assessment (TRA) to address India’s data protection gaps.
Technical measures of encryption during transit.
You have the right to obtain a copy of the SCCs by emailing <contact@ikivana.com>. Transfers are minimized and occur only with your consent. For further details, see ICO guidance on international transfers (ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers).
7. How Long We Keep Your Personal Data
We retain your data only as long as necessary for the purpose (typically until after the Fertility Connect Call is completed or you withdraw consent, up to 6 months). After this, we securely delete it using industry-standard methods (e.g., overwriting or certified destruction). If a legal obligation applies (e.g., audit), we retain anonymized records.
8. Your Rights
Under UK GDPR, you have rights regarding your data:
Access: Request a copy (free, subject to limits).
Rectification: Correct inaccuracies.
Erasure (“right to be forgotten”): Delete data (except where legally required).
Restriction: Limit processing in certain cases.
Portability: Receive data in a structured format.
Object: Oppose processing (e.g., on legitimate interests, though we use consent).
Withdraw Consent: At any time, without affecting prior processing – email <contact@ikivana.com> or use the unsubscribe link.
To exercise rights, contact us at <contact@ikivana.com>. We respond within one month (extendable to three for complex requests). No fees apply unless requests are excessive. If unsatisfied, complain to the ICO (ico.org.uk/make-a-complaint; helpline: 0303 123 1113).
We may verify your identity before responding to prevent unauthorized access.
9. Security
We protect your data with appropriate technical (e.g., encryption, firewalls) and organizational measures (e.g., access controls, staff training). As a small business, we conduct regular risk assessments but note no system is 100% secure – report suspected breaches to us immediately.
10. Children’s Data
The Site is not for children under 18. We do not knowingly collect data from minors. If we discover such data, we delete it promptly. Parents/guardians can contact us for access/erasure.
11. Changes to This Policy
We may update this policy to reflect legal changes or operations. We notify you via email or Site notice. Continued use constitutes acceptance. Check regularly.
12. Third-Party Links
The Site may link to external sites (e.g., HFEA or GMC resources). We are not responsible for their privacy practices – review theirs separately.
For questions, contact <contact@ikivana.com>. This policy aligns with ICO best practices for small organizations.