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IMPORTANT DEFINITIONS

Everywhere in this Privacy Notice:

  • “Worldwide”, “we”, “us”, and “our” mean Worldwide Surrogacy Specialists LLC.
  • “You” and “your” refer to the individual who the personal data is about.
  • “Process” and “processing” mean all the actions that Worldwide performs on your personal data, including collection, use, sharing, securing, and eventual destruction.
  • “Personal data” or “data” is any information that does, or could, identify you.
  • “Special categories” of data means particularly sensitive data like that concerning health, sex life, ethnic origin, and criminal offences.

1. INTRODUCTION AND SCOPE

Worldwide understands that you provide your data to us in the expectation that we will protect it, treat it as confidential, and allow you to exercise your rights over it. This Privacy Notice describes how we process your data and how you can exercise your rights.

This Notice is addressed principally to our customers and clients (intended parents) and surrogates, but applies also to other relationships you may have with us, for example as a prospective customer or candidate surrogate. The Notice does not, however, apply to Worldwide’s employees and contractors.

Unless otherwise stated, this Notice applies globally, regardless of your geographical location.

2. CHANGES TO THIS NOTICE

We may update this Notice from time to time and will tell you about material changes through the most effective channel, usually the e-mail address we hold for you. The Notice was last updated on October 8th, 2019.

3. PERSONAL DATA COLLECTED

In nearly all circumstances, the data we process about you is provided by you yourself, or collected with your explicit authorization. This data is collected, for example, on application forms, during interviews, or as a result of background checks that you have approved. Worldwide is acutely aware of the intimate and sensitive nature of much of this data and of our duty to protect it.

You do not have to provide your data to us, but failure to do so is likely to make it impossible for Worldwide to process your application to be a parent or surrogate.

We also collect data about you when you interact with us online. We collect this data using cookies and other standard online technologies. Cookies allow us to recognize your device. We collect information about how you use our website, for example what pages you visited and how long you stayed on them.

4. PURPOSES OF PROCESSING

We use your personal data first and foremost to provide our services to you, for example to:

  • Respond to your enquiries
  • Process your application, which includes assessing your suitability to be a parent or surrogate
  • Support you during your path to pregnancy and pregnancy, whether as parent or surrogate
  • Carry out standard business functions like invoicing and online authentication

We use your data to help us improve our services and online experiences, for example to identify which parts of our website our visitors find useful. Usually, the data used for this purpose is not directly attributable to you as an individual.

Marketing: We may use your data to contact you about our services and business after you have indicated an interest in them. When required by your local law, we will obtain your prior consent. See Section 9, Your Privacy Rights for information about exercising your marketing preferences.

EU General Data Protection Regulation (GDPR) lawfulness of processing

The GDPR requires us to provide information about our legal bases for processing the data of individuals in the European Union. Our legal basis depends on the purpose of processing and the type of data:

Purpose of processing Legal basis
Provide our services to you

1. GDPR Article 6,1(b) – to take steps toward, or to perform, a contract with you.

2. When we process “special categories of personal data” in order to provide our services to you, we do so with your consent.

Improve our services and online experiences GDPR Article 6,1(f) – our legitimate interests in improving our services and online media.
Market our services to you GDPR Article 6,1(a) – your consent.

5. RECIPIENTS OF YOUR DATA

In order to achieve the purposes described above, Worldwide may disclose your data to various individuals and organizations:

  • Our employees and contractors who have a “need to know” and who have signed a confidentiality agreement covering your data as a condition of their employment with us.
  • Service providers (“processors”) who process your data on our behalf and per our instructions; for example, our Cloud storage provider, CRM software-as-a-service vendor, and web marketing services company. These service providers are contractually bound to protect your data to the same standard as Worldwide and are prohibited from using it for their own purposes.
  • Legal and healthcare professionals who help us process your application and support you during your path to pregnancy and pregnancy. These specialists are governed by rules of professional conduct and privacy standards.
  • Your data may be transferred to third parties as a result of a merger, acquisition, or similar corporate event involving Worldwide.
  • We will disclose your personal data if compelled by law.

Worldwide will never sell your personal data or otherwise disclose it for commercial gain.

6. DATA SECURITY

Worldwide employs—and continually reviews—administrative, technical, and physical security measures appropriate to the sensitive nature of the personal data that you provide to us. These measures include, for example, firewalls, roles-based access, and current security patches. It is, however, impossible to guarantee that personal data will never be accidentally or illegally breached.

7. DATA RETENTION

In principle, we store your data for the period of your relationship with us and thereafter only as necessary to satisfy legal, accounting, and other obligations or to resolve disputes.

If you are an intended parent or surrogate, we will retain your records for seven years from the end of the appropriate contract governing your pregnancy. After this period, we will delete all electronic copies of your data and securely destroy all paper copies.

Please note that our data retention policy does not affect your right (see Section 9) to request erasure of the data that we hold about you.

8. INTERNATIONAL TRANSFER

Worldwide is a United States company. If you live outside the US, your data will be transferred to the US for processing. US privacy laws may be very different from those of your country. However, as described in this Notice, Worldwide takes steps to protect your data and your privacy rights after international transfer.

Worldwide’s transfer to the US of the data of EU residents is permitted by EU law (GDPR) on the basis that it is necessary to take steps toward or to perform a contract between you and us.

9. YOUR PRIVACY RIGHTS

You may at any time request:

  1. Access to the data that we hold about you
  2. Correction of inaccuracies in the data
  3. That we cease to process the data
  4. That we delete the data
  5. Information about data portability

When we process your data based on your consent, you may withdraw that consent at any time.

You can make these requests and take these actions using the contact information provided in Section 10.

Marketing: We strive to ensure that our marketing communications are only received by individuals with an interest in our services. When required by your local law, this means obtaining your prior consent. However, if you receive unwanted marketing messages from us, please use the opt-out mechanism, if available, or contact us so that we can remove you from our marketing list.

If you believe that we have infringed your privacy rights, please contact us so that we can try to resolve the issue. However, if you are an EU resident, you have the right to lodge a complaint with your local supervisory authority.

10. CONTACT US

Privacy enquiries and Data Protection Officer: privacy@worldwidesurrogacy.org

Worldwide Surrogacy LLC
2150 Post Road
Fairfield, CT 06824
USA www.worldwidesurrogacy.org