Please read this policy carefully to understand out policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our website or service.
What information do we collect?
We collect information from you in three instances.
Education: When you fill out a form requesting more information regarding our services, we request some basic contact information about you and your partner such as name, phone number, and email address..
Screening: When you request a personal consultation, so that you can find out more about our services, and we can evaluate whether your eligibility for our service, we request additional information from you through our online form, including not only contact information, but also additional information regarding your health, employment, insurance, and other information that is needed for us to evaluate your qualifications for our service.
Supporting: When we agree to work together, as we support you in your journey as a prospective parent, donor or surrogate, we will request additional information from you as is necessary to perform or facilitate the health, legal, insurance and other services for you.
When registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address or phone number. You may, however, visit our site anonymously.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
To educate you about out services, we may use the information we collect:
To personalize your experience
(your information helps us to better respond to your individual needs)
To improve our website
(we continually strive to improve our website offerings based on the information and feedback we receive from you)
To improve customer service
(your information helps us to more effectively respond to your customer service requests and support needs)
To send periodic emails
The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
When you participate in our screening and evaluation process, we use the additional information you provide to verify your identity and to evaluate your eligibility for our service.
When we agree that you will use our services to support you in your journey, we use the additional information that you provide us, as well as the agreements that you sign with us to allow us to perform or facilitate the health, legal, insurance and other services for you the service.
How do we protect your information?
We implement a variety of technical, administrative and logical security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We do provide limited amounts of personally identifiable information to trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential; however we strive to minimize the information to what is necessary for a particular services. For example, third parties that assist us in operating our website or understanding how people use our website, may receive information such as IP address or cookie IDs but would not receive contact or other more sensitive identifiable information as such more detailed information is unnecessary for the services they are providing us. As a further example, if you request more information from us through our website, we may ask for contact information so that we can respond, inform you about our services, or provide you with other marketing types of information and we may provide this information to third parties that assist us in these marketing and advertising programs. On the other hand, if you apply to participate in our screening and evaluation sessions, the information we need to provide to trusted third parties to assist us in our evaluation processes may be more robust with the type of work that needs to be performed to conduct the evaluations and screening. Finally, if you enter into a contract with us to allow us to support you in your journey as a parent, donor or surrogate, we will require much more information from you and as we will need to provide your information as necessary to trusted third parties such as insurance companies, health care providers, members of the legal community, and others that may be needed to provide the services to you. Any use of this information is made in accordance with contracts we have with these third parties and/or with you.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We do provide certain personally identifiable information toThis does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. For example, if you request information from us, we provide your information to service providers that help us with our marketing and advertising initiatives; if you participate in our screening and evaluation sessions, we provide your information to trusted third parties to assist us in our evaluation processes; or if you agree to work with us as we support you in your journey as a parent, donor or surrogate, we provide your information as necessary to trusted third parties such as insurance companies, health care providers, members of the legal community, and others that may be needed to provide the services to you.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, from time to time, we provide non-personally identifiable website visit or traffic or information regarding our users, may be provided to other parties for marketing, advertising, and otherwise to help us support our business or other uses. Any use of this information is made in accordance with contracts we have with these third parties, and are subject to their privacy policies.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We encourage you to review the privacy policies for those sites to understand how they collect and use your information. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Children's Online Privacy Protection Act Compliance
Our website, products and services are all directed to people who are at least 18 years old or older. We do not knowingly collect personal information from children under 13.
If you believe we might have received information from a child under 13, please contact us at [email protected] We are in compliance with the requirements of COPPA (Children's Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
Non-US Users; Users from the European economic area
If you are located in the European Economic Area (“EEA”), please note the following:
Data transfer: In order to ensure that your information is protected when transferred out of the EEA, we rely on standard contractual clauses approved by the European Commission or by adopting other means to ensure that adequate safeguards are applied.
Individual data rights: Individuals from the EEA have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, object to or limit the use of your personal data, or to request data portability. If you wish to exercise these rights, please reach out to us at [email protected].
Legal basis: We note, for individual from the EEA, that when we obtain your personal data we serve as a data controller, and we process your personal data pursuant to consent (such as, when you provide us with registration information), contract (when you enter into an agreement with us to participate in our service) or to pursue legitimate business interests described above (such as to support direct marketing efforts). If you wish to withdraw consent previously provided to us, please contact us at the contact information below. If you have entered into a contract with us, we ask that you refer back to the contract with regards to your rights and obligations. IYf you believe that your personal information has been used in a manner that is not consistent with the relevant privacy policies listed above, please contact us using the information below. You have a right to make a complaint regarding our data practices with the applicable supervisory authority in the members state of your residence.
Data Retention: For individuals in the EEA, our policy is to retain your personal data as follows: for individuals requesting education regarding our service information or applying for our service, we will retain your personal data for up to 3 years; for individuals that participate in our screening and evaluation processes, we will retain your information for up to 7 years as we have found that important decisions such as this one, often take a number of years and to make, If you enter into an agreement with us to work with us as we support your journey as a parent, we will unless you decide to participate in our service. If you decide to participate in our service, we will retain your personal data until you instruct us to delete such information, as we offer ongoing service, contact, medical and legal support throughout your future child(ren)’s lifetime. We may retain your information beyond these retention periods n as we ha until you terminate your account, or otherwise if needed to meet outstanding contractual requirements, retention requirements imposed by a legal process, health requirements, or for similar mandated operational or similar audit requirements.
You can make changes to, or request, your information at any time by clicking here.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (CCPA) creates new consumer rights for residents of the state of California relating to the access to, deletion of, and sharing of personal information that is collected by businesses. Under this act, California consumers have the right to know what personal information is collected, used, shared or sold; and they have the right to:
• Request personal information held by businesses be deleted
• Opt out of the sale of personal information
You can learn more here.
You can make changes to, or request, your information at any time by clicking here.
This policy was last modified on January 17, 2020.
Circle Surrogacy, LLC
200 High Street, Suite 600
Boston, MA 02110