Surrogacy Place LLC (“we”, “us”, or “our”) wants you to be familiar with how we utilize, collect, and disclose the information you provide to us directly or via third-party services that collect through our website and web-based properties (e.g. applications) (each, a “ Property ” or collectively the “ Properties ”) and the choices you have associated with that data. Please read this Privacy Policy thoroughly before using our website. By using this service and providing Personal Information (as defined below), you acknowledge that you have read this Privacy Policy and understand the terms and conditions herein, and that you agree to the collection and use of information in accordance with this Privacy Policy.

Please note: we are not responsible for the privacy policies or other practices of any third party, including Facebook, Inc., Google LLC, Apple Inc., Microsoft Corp., wireless carriers and any third party operating any property to which any Property contains a link. In addition, the inclusion of a link on any Property does not imply endorsement of, or affiliation with, the linked site by us. Properties may include the ability to access and submit (including, for example, via a third-party software application or service that is available through or in connection with the Property) certain information directly to third parties or to any application platform. Such information is submitted by you directly to such third parties and this Privacy Policy does not apply to any such information submitted by you.    

Our Properties use the following third-party applications to provide you with Surrogacy Place’s core Site services: imgix (to process user-uploaded photos), DigiSigner (to enable an electronic acknowledgement of this Privacy Policy and our Terms & Conditions ), Stripe (for payment processing and ID verification), and Amazon Web Services (web hosting and storage services).

Surrogacy Place complies with the California Consumer Privacy Act (“CCPA”) and will not Sell your Personal Information.  For purposes of Article 14(2) of the EU General Data Protection Regulation (“GDPR”), Surrogacy Place relies on the following lawful basis for processing Personal Data: consent, compliance with law and legitimate interest. Surrogacy Place does not differentiate how we treat our users whether they exercise their rights under the CCPA.  

PERSONAL INFORMATION

Personal Information We May Collect

There are two types of information collected within the Properties: Personal Information and Other Information. “Personal Information” is information that identifies you or makes you identifiable as an individual. “Other Information”  is any information that does not reveal your specific identity. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as details in this Policy. Other Information is addressed separately below, under the heading “OTHER INFORMATION”.

We urge you to be very careful when deciding to disclose your Personal Information, or any Other Information, on or through the Properties. We are not responsible for the use or disclosure of any information you voluntarily disclose through any Property.

We and our third-party service providers may collect the following Personal Information from you:

-Name (as verified by your provided government ID)

-Age (as verified by your provided government ID)

-Mailing and billing addresses

-Email address

-Telephone number

- Credit/debit card number/mobile payment service information

-Your IP address

-Photos

-Photo of government issued identification (driver’s license, passport, etc.)

-When you create a profile on the Property, you will be asked to provide personal information including name, email address, demographic information (e.g. location, nationality, age, gender, ethnicity, sexual orientation, religion, languages spoken), personal characteristics (including medical and physical information), as well as views on reproductive health choices and other potentially controversial topics. You will also be asked to provide information about your family and children/spouses (if applicable) and be required to use your legal name as verified by a government ID. You will be asked to upload one or more photograph(s) and to provide a personal description telling other registered users personal details about yourself.

Because of the nature of the services we provide, we do not allow profiles that include incomplete personal information. In deciding to use the Property, you acknowledge that you are choosing to share personally identifiable information with us and with other users of the Property. Using pseudonymous data is prohibited. For more information on who can use our site, please visit our terms and conditions .

We and our third-party service providers collect Personal Information through the Properties in a variety of ways, including:

-Directly through the Properties. For example, when you register as a user of the Property or contact us for information.

-From other sources. If you use your social media profiles or third-party account details on our Properties, you will share Personal Information from your third-party account with us which may include your name, email address, photo, list of social media contacts and any other information which is otherwise accessible to us when you connect with us through such a third-party account.

You are not required by statute or contract to provide any Personal Information to us, however, when you participate in services provided through the Properties, we must collect Personal Information from you in order to enable us to provide our services.

We and our third-party service provides use Personal Information we collect, including personally identifiable information, for the following business purposes:

-To provide the Properties’ functionality and services to you, such as arranging access to your registered account and those of potential matches, and providing you with related customer service.

-To allow users to find other users based on preferences and/or user location.

-To promote your profile to other users of the Property.

-To filter and customize content and information that we send or display to you, to offer profile customization, and personalized help and instructions, and to otherwise provide a personalized experience to you while using the Property.

-To detect and combat fraud.

-To deliver offers to you from third-party companies.

-To manage your account and provide you with customer support.

-To enforce our Terms and Conditions.

-To save your user account and profile data and other information.

-To track your visits and use of services provided by the Properties.

-To respond to your inquiries when you contact us or otherwise when you send us questions, suggestions, or complaints, or when you request information about our Properties.

-To send you administrative information, including information regarding the Properties and changes to our terms, conditions, and policies.

-To process your payments and communicate with you regarding customer service.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Analysis of Personal Information for business reporting and providing personalized services.

-To analyze or predict our users’ preferences in order to prepare aggregated trend reports so we can improve our Property.

-To personalize your experience on the Properties using your IP address and/or location matching.

Aggregating and/or anonymizing Personal Information.

-We may aggregate and anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose. We will engage in this activity where we have a legitimate interest.

Accomplishing our business purposes.

-Data analysis, for example, to improve the efficiency of our Properties;

-Audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

-For fraud and security monitoring purposes, for example to detect and prevent cyberattacks or attempts to commit identity theft.

-For developing new products and services;

-For enhancing, improving, or modifying our current products and services;

-For determining the effectiveness of promotional campaigns, so we can adopt our campaigns to the needs and interests of our users; and

-For operating and expanding our business activities, for example, understanding which parts of our Properties are of most interest to our users so we can focus on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information

We disclose Personal Information:

-To other registered users of the site to enable the services we provide. We may disclose details of your profile, including Personal Information, to other users of the Properties. By providing us with your personally identifiable information and using the Properties, you consent to the transfer of your personally identifiable information to countries outside of your jurisdiction of residence.

-Your Personal Information, including profile information and any information you provide to the Properties, will be available and searchable by other users of the Properties.

-To trusted third-party service providers, to facilitate the services they provide to us. These can include providers of services such as hosting, data analysis, payment processing, IT services, customer service, email delivery, payment processing, auditing, or other similar services to allow them to provide such services.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have the legal obligation or legitimate interest to do so:

-To comply with applicable law. This can include laws outside your country of residence.

-To respond to requests from government authorities. This can include authorities outside your country of residence.

-To cooperate with law enforcement. For example, when we are responding to law enforcement requests and orders.

-For other legal reasons including to enforce our terms and conditions, to protect our operations, to protect our rights, privacy, safety, or property, as well as the rights of you or others.

-To protect and defend our rights or property and against liability.

 In Connection with a Business Transaction

-We may have a legitimate interest in transferring your Personal Information to a third party in the event of a sale, joint venture, assignment, transfer or other disposition of all or any portion of our business. Such third parties may include any acquiring entity and its advisors.

Retention Period

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria we use to determine our retention periods include:

-The length of time we have an ongoing relationship with you and provide the Properties to you (for example, for as long as you have an account with us or keep using the Properties);

-Whether this is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

-Whether retention is advisable in light of legal position such as in regard to applicable statues of limitations or litigation.

 

Updates to Your Personal Information

-You may modify/update most of the personally identifiable information you have provided at any time by going to “Manage Profile” or “Account Settings” sections of your profile. Please be aware it may take hours for any changes you make to take effect and be publicly visible on your profile. You may not update the name or age on your profile. These must match the details on your provided and verified government ID.  You can delete your profile at any time in the “Account Settings” section of your profile under “Delete Profile”.

Some Personal Information Will Not be Visible to the Public

-This includes your billing address, credit card/payment details, telephone number, and IP address.

 

OTHER INFORMATION

We and our third-part service providers may collect Other Information such as:

-Browser and device information

-Mobile App usage data

-Server log files

-Information collected through cookies, pixel tags, and other technologies.

-Geographic location information

-Demographic information and other non-personally identifiable information as provided by you

-Information about how you use the Properties

 

How We May Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

-Through your browser or your device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Mac or Windows), screen resolution, operating system, internet browser, and the type and which version of the Property you are using. We and our service providers may also collect a unique device identifier assigned by us or our service providers to the device which you are accessing the Property and other transactional information for the device that we and our service providers may use to serve content to the device.

-Through your use of Mobile Apps: When you download or use a mobile app, we and our service providers may track and collect Mobile App usage data, such as the date and time the mobile app on your device accesses our servers and what information and files have been downloaded to the mobile app based on your device number.

-Through server log files:  An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing a Property by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Property, along with the time of the visit and the activity on the Property. We and our service providers use IP addresses for purposes such as calculating Property usage levels, helping diagnose server problems, administering the Properties, preventing fraud, and determining your approximate geographic location.

-Using cookies : We and our service providers may use cookies, pixel tags, JavaScript, web beacons, Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) and other similar technologies to, among other things, better serve you with more tailored information about our services, facilitate your ongoing access to and use of Properties, and collect and store information about your use of the Properties. For example, pixel tags and web beacons may be used in connection with a Property to, among other things, track the actions of such Property’s users and compile statistics about Property usage.

                   If you do not want information collected through the use of cookies, there is a simple procedure on most devices through which the Properties are accessed that allows you to decline the use of cookies. If you choose to decline cookies, then some of the features and functionality available through the Properties may not be available to you. For more information on what cookies are, how they work, and how to disable them, visit www.allaboutcookies.org.

                   If your device stores Flash LSOs and you do not want Flash LSOs stored on your device through which you access the Properties, you can adjust the settings of your Flash player to block Flash LSO storage. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Properties or our content.

                   The use of these technologies allows our vendors and third parties and their vendors to deliver advertisements about our services. These parties may place so-called “pixel tags”, “web beacons”, “clear GIFS” or similar technologies on the device through which you access the Properties, or other applications or websites across the Internet, and also place or recognize third-party cookies when you use the Properties or other applications, websites, or web properties. They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile device or laptop. These vendors and third parties may use information about your visits, on the different devices you use, to the Properties, or other applications, websites or web properties (excluding your name, address, and telephone number) as well as information received from third parties to provide advertisements for you and others about goods and services that may be of interest to you.

-Through Third-Party Analytics such as Google Analytics.  We use these applications to evaluate usage of our Properties and the services we provide. Third-Party Analytics provides may use cookies and other technologies to perform their services and combine information they collect about you on our Properties with information they have collected. This Privacy Policy does not cover third-party use of data.  

-Third-Party Links . Our Properties may contain links to third-party websites and applications which may collect personally identifiable information. We do not supply personally identifiable information to these third parties and are not responsible for their Privacy Policies, nor is the information they may collect governed by this Privacy Policy.

-Geographic location information:  If you use any location-enabled products or services, you may be sending us location information. When you use a location-enabled service, we may collect and process information about your precise geographic location, such as GPS signals sent by a mobile device. We and our third-party service providers and partners may use your device’s physical location to provide you with personalized location-based services, content, and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.

-Information about how you interact on the Properties. We may collect information about how you interact on the Properties. This collected information may let us know which services and features you are using the most within the Property, as well as device type and hardware features, country and language, etc.

-By aggregating information. We may aggregate Personal Information so that the end-product does not personally identify you or any other use of Properties, for example, by using Personal Information to calculate the percentage of our users who fall into specific demographics.

Please note:  our Properties do not respond to browser-based “do not track” signals.

 

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in “How We May Collect Other Information” section above as well as for all the purposes for which we use and disclose Personal Information.  In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographic location). If we combine any Other Information with Personal Information, the combined information will be treated as Personal Information.

SECURITY

We will use reasonable technical and administrative measures to protect Personal Information under our control. The security of your data is important to us, however, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately by emailing help@surrogacyplace.com.

We do not monitor communication between users’ private exchanges, though we reserve the right to do so if we suspect users are violating our Terms & Conditions or Privacy Policy. We reserve the right to edit, delete or remove any communication in any public area of a Property that violates our policies.

 

CHILDREN’S PRIVACY

All users to this site must be over the age of 21. We do not knowingly collect personally identifiable information from anyone under the age of 21. When filling out your profile, all users should take care to not include names/ages and other personally identifiable information of children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take steps to remove that information from our servers.

 

CHOICES AND ACCESS

-You may opt-out of receiving marketing related emails from us and our affiliates at any time by emailing help@surrogacyplace.com.

-If you would like to access, review, correct, update or delete Personal Information that you provided to us with the exception of your name and age, you may use the “Manage Profile” or “Account Settings” sections of the site. You may also contact us directly at help@surrogacyplace.com. Please note: we may need to retain certain information for recordkeeping and/or to complete any transactions that were already in progress.

 

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time. Please see the “last updated” notation at the top of this page to see when this Privacy Policy was last revised. We will provide a minimum of (30) days written notice prior to the implementation of any material changes to our privacy policy and to obtain your consent as required by applicable law.

TRANSFER OF DATA

The Properties are controlled and operated from the United States of America. This Privacy Policy and use and disclosure of Personal Information is governed by the laws of the United States of America. Your Personal Information may be stored and processed in any country and by using the Properties you understand that your data may be transferred to countries outside of your country of residence which may have data protection rules that are different from those of your own country. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there

As a European citizen, under GDPR, you have certain individual rights. You can learn more about these at: https://eugdpr.org/

 

CONTACT US

If you have any questions related to this Privacy Policy or any of our Terms & Conditions, you may contact us at help@surrogacyplace.com  or Surrogacy Place LLC: 90 State Street #700; Office 40; Albany, NY 12207.