Effective Date: 8/18/2022
1.TYPES OF INFORMATION WE COLLECT
We collect various types of information in connection with our Services, including information personally identifiable to you (which we call “Personal Information”):
- Account Information. When you create an account or otherwise engage with our Services, you may provide certain details like your name, email address, phone number, date of birth, and other information. Depending on the Services you use, we may also collect information from you or third parties to help determine eligibility for our programs, provide the Services, and help you along the way. This may include details like your medical history, location, answers to questionnaires, and/or evaluations performed by third parties, some of which may be considered Health Information (defined below).
- Site Activity. We may track certain actions you take across our Sites or Services, for example, the content of searches and information you enter.
- Usage Information. We may collect details about your use of our Sites or Services, like pages you view, services and features you interact with, and details about links or communications you interact with.
- Device and Browser Information. We may collect details from or about devices you use to access our Services, like internet protocol address, browser type, connection speed, device model, operating system, and access times.
- Information from Cookies and other Technologies. We or our service providers may use commonly used tools like browser and/or flash cookies, web beacons, pixels, local shared objects, and similar technologies (“Cookies”). For more details or to exercise preferences, see Section 10.
- Payment Information. Depending on the Services you use, you might provide payment information like bank account numbers, credit or debit card numbers, account details, ACH information, and similar data. Payment Information will be collected and processed by third-party payment processors in accordance with their privacy policies and terms. We do not access or store Payment Information.
- Social and Community Content. We may receive content you post on social media and community pages related to the Services.
- Information from Others. We may obtain information about you from other users, like your partner or spouse.
In some cases, the information above is non-personal information. For example, information collected through Cookies may not contain any Personal Information. We will still treat it as Personal Information if it’s considered Personal Information under an applicable law, or if we combine it with Personal Information.
2. HOW WE USE PERSONAL INFORMATION
We may use your Personal Information for various purposes, including to:
- Provide and improve our Services;
- Notify you of changes to our Services, terms, or policies;
- Personalize your experience or otherwise customize what you see when you access our Services;
- Provide information, products, or services you request, or details about others we think will interest you;
- Fulfill any other purpose for which you provide Personal Information;
- Allow you to participate in interactive features of our Services;
- Send marketing and promotions, whether by email, phone, or text;
- Create and report aggregate, de-identified information (such as aggregate statistics relating to use of our Services) for use in research and for marketing, promoting, improving, and developing our Services;
- Administer surveys, sweepstakes, promotions, or contests;
- Provide any other services you request, contact you about your account, or respond to your questions;
- Provide, analyze, and improve interest-based advertising;
- Carry out obligations or enforce our rights under any contracts between you and us; or
- To fulfill any other purpose, with your consent.
3. HOW WE SHARE PERSONAL INFORMATION
We may disclose Personal Information to third parties in certain cases, for example:
- To our subsidiaries, affiliates, and associated organizations;
- To contractors, service providers, and other third parties we use to support our business, who are contractually required to keep it confidential;
- To third parties authorized by you, like clinics, egg banks, egg storage facilities, and others in connection with the Services. If you participate in our Split Program, this includes providing certain information to intended parents as described in the Split Program Agreement;
- As required by law, for example, as required by a court order or subpoena;
- When we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our Services, our customers, or others;
- To prevent fraud, cybersecurity attacks, or illegal activity;
- In connection with a merger, consolidation, restructuring, sale of company stock and/or assets, or other corporate change, including in the course of any due diligence process;
- As part of an aggregated, de-identified data set, either publicly or with our affiliates, subsidiaries, and partners;
- For any other purpose disclosed by us when you provide the information or with your consent; or
- If it’s de-identified information (information that is neither used nor intended to be used to personally identify someone), for any purpose without restriction.
We do not and will not sell lists of registered users.
4. HEALTH INFORMATION
In connection with our Services, you or a third party may provide certain Health Information to us. By “Health Information,” we mean any Personal Information regarding your medical history, mental or physical condition, or treatment. We are not a covered entity under federal privacy law (i.e., the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations, or “HIPAA”). In the event that we function as a business associate to a covered entity, we comply with HIPAA and the covered entity’s Notice of Privacy Practices. We know that Health Information is sensitive and we take extra precautions to ensure its confidentiality, even if not required by law.
You may need to sign an authorization for a third party like a clinic to provide your Health Information to us. Where we use third parties to process your Health Information, we prohibit them from further disclosing or using it except in connection with our Services. If we need to disclose your Health Information to a third party (like a clinic, egg bank, or otherwise), we’ll get your separate consent before doing so.
5. COMMUNICATION WITH OTHER USERS
In connection with our Services, we offer ways to communicate with users. We’ll do our best to keep these conversations among the intended audience (like your cohort) and we require users to comply with Community Guidelines. That said, we can’t control how other users share what you discuss, so if you share Personal Information with others, keep in mind that it may be shared outside our Services.
Our Services are not intended for children under 18. In line with the Children’s Online Privacy Protection Act, we will never knowingly request or solicit Personal Information from anyone under 13 without verifiable parental consent. If we learn that we have collected that information from anyone under 13 without verifiable parental consent, we will promptly delete it. If you believe we’ve collected Personal Information from someone under 18, please contact us at firstname.lastname@example.org.
7. INFORMATION SECURITY
We use reasonable physical, electronic, and managerial security methods (such as encryption) to help protect against unauthorized data access. But please be aware that no data transmission over the Internet or data storage facility is guaranteed to be perfectly secure. As a result, we cannot ensure or guarantee the security of any information you transmit to us.
8. INFORMATION RIGHTS AND CHOICES; DELETION AND RETENTION
We offer a number of ways to manage Personal Information and privacy, including:
- You can edit or correct information or settings through your Member Portal.
- You can manage cookies and tracking preferences by visiting the NAI Opt-Out Page and the Choices Opt-Out Page, or through device or browser settings.
- You can delete Personal Information, manage marketing preferences, or limit certain information sharing by reaching out to email@example.com.
9. CALIFORNIA PRIVACY RIGHTS
Under California law, California residents have the right to make certain requests or choices related to their data, free of charge. This includes a “right to know” about personal information collected by a business and how it’s used or shared, including whether personal information has been shared or sold for a business purpose. The term "personal information" in this section is referring to how that term is defined under California law.
If you are a California resident, you may have the following rights:
Access and right to know. You may have the right to access or know about:
- the categories and specific pieces of personal information collected about you (and the sources it came from),
- the purpose for collecting that information,
- the categories of third parties with whom it was shared,
- the categories of any Personal Information sold and who it was sold to, and
- the categories of Personal Information disclosed for a business purpose.
Deletion. You may have the right, in some cases, to request that we delete personal information you have provided to us. Please note, there may be some cases where we are not required to delete the information (see Section 8).
Non-discrimination. We will never discriminate against you for exercising any of your rights under California law.
No Sale of Personal Information. California law offers the right to opt out of the sale of personal information. As described above, we do not sell lists of registered users.However, we may use or share that Personal Health Information for certain other business purposes described above, like advertising.
To exercise any rights available to you, please email us at firstname.lastname@example.org. To help protect your information from unauthorized access or deletion, you’ll need to include enough information to identify you (for example, full name), proof of your identity and address (for example, a copy of your driver's license or passport and a recent utility or credit card bill), and a detailed description of the request. This information will only be used to verify your identity. If you don’t have an account, or if we believe your account may have been misused, we may ask you for additional verifying information. If we can’t confirm your identity, we may refuse the request.
Note: you can use an authorized agent to submit a request. If you do, they’ll either need to show they have power of attorney to act on your behalf, or they’ll need to provide a signed written authorization to act on your behalf - in which case you’ll need to independently verify your identity and confirm that you provided permission.
We may use both session Cookies (which expire once you close your browser) and persistent Cookies (which don’t) to make our Services easier to use, fulfill your requests, personalize and improve experiences, improve advertising, and protect both you and us. We use “strictly necessary” and “functionality” Cookies to support functionality and security by collecting crash analytics and Site activity data, and providing security measures.
Depending on the choices and settings available for your browser, you may be able to disable cookies in your browser settings, though it could affect the availability and functionality of our Services. If you prefer to opt out of having your web viewing behavior used for interest-based advertising, please visit the NAI Opt-Out Page here. To opt out of having information about your mobile app usage used for interest-based advertising, please update your mobile device settings. Note, you may still receive generic ads that are not based on your preferences.
11. GENERAL TERMS
12. CONTACT US