EGG DONOR CONNECT, LLC
Privacy Policy

Last updated September 12, 2025

Egg Donor Connect, LLC (“EDC,” “us,” “our” or “we”) is committed to protecting your privacy. “You/your/user(s)” means you as a user of our Services, including any information, tools and services available from the Services. Our privacy policy, which applies to all users of our Services (“Users”), is designed to explain the information we collect and how we use it to provide our Services and give Users a better experience (“Privacy Policy”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at https://www.eggdonorconnect.com/TermsOfUse/. This Privacy Policy is part of, and incorporated into, the Terms of Use.

This Privacy Policy describes the Personal Information (as defined below) we collect about you through the Services, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information. The Personal Information provided by you is not used for any purpose other than as described in this Privacy Policy.

By accessing and using the Website you are agreeing to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to provide you with specific products or services, we may not be able to provide those products or services to you.

We collect demographic, health and/or health-related identifiable information about you from or on behalf of your doctors, healthcare specialists, professionals, providers, Clinic(s) (as defined herein), or organizations (“Healthcare Providers”), and such information may be considered “protected health information” (“PHI”) under the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Clinical Health Act of the American Recovery and Reinvestment Act of 2009, and their respective implementing regulations as amended from time to time (collectively “HIPAA”). EDC will only use and disclose PHI as part of providing the Services and as outlined in this Privacy Policy, and we will do so in compliance with the specific PHI privacy and security protections provided in HIPPA, as permitted pursuant to the agreements between us and the Healthcare Providers we work with, and in accordance with applicable law.

1. KEY DEFINITIONS

1.1 “AI” or “Artificial Intelligence” means computer systems, software, or algorithms, including machine learning models and large language models, that are designed to perform tasks that typically require human intelligence, such as understanding language, generating content, answering questions, analyzing data, or making predictions or recommendations. For purposes of this Privacy Policy, “AI” includes any automated tools or agents used to process, analyze, or generate information in connection with the Services.

1.2 “AI Output” means any chart, insight, prediction, recommendation, text, image or other material generated autonomously or semi-autonomously by the Service.

1.3 “Biometric Information” means an individual's physiological, biological, or behavioral characteristics, including information about an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric Information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

1.4 “Clinic” means a health care facility, typically a fertility or reproductive medicine center, that partners with EDC to facilitate egg donation and family building services through our Services. Clinics are responsible for managing all aspects of the egg donation process, including screening donors, conducting medical procedures for egg retrieval, and supporting Intended Parents in accessing donor eggs. Clinics serve as the primary point of contact for both Donors and Intended Parents during medical evaluations, procedures, and follow-up throughout the fertility journey.

1.5 “Donor” means a person who provides eggs and shares information about themselves through the Service so that Intended Parents can find and potentially choose them as an egg donor.

1.6 “Donor Questionnaire” means the intake form completed by an individual interested in becoming a Donor. The Donor Questionnaire involves the collection of Personal Information, including Personal Health Information, for use by Healthcare Providers in assessing the individual’s suitability to serve as a Donor.

1.7 “Intended Parent(s)” means any individual or individuals using the Services for the purpose of locating, evaluating, and potentially engaging with Donors in order to achieve parenthood.

1.8 “Model” means any algorithmic architecture, machine-learning system (including weights, parameters and prompts) or ensemble thereof that powers generation of AI Output.

1.9 “Personal Information” means any information that identifies or relates to a particular individual and includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations.

1.10 “Sensitive Personal Information” means Personal Information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, Personal Information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, Biometric Information, or citizenship and immigration status.

1.11 “Special Category Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.

Capitalized terms not defined here have the meanings given in the Terms of Service located at https://www.eggdonorconnect.com/termsofuse.

2. TYPES OF INFORMATION WE COLLECT

2.1 Personal Information that we collect about you

We collect Personal Information about our users as part of their activities on our Website and Services. Such information may include:

  • Contact Information: such as your first name, last name, phone number, and street address.
  • Other Information You Provide: such as comments, company name and address, title, and education.
  • Payment and Account Information: such as username and/or e-mail address in combination with a password or security questions and answers, and account numbers or credit/debit card numbers, even without a security code, access code, or password if the account could be accessed without such information.
  • Sensitive Personal Information and/or Special Category Personal Information: such as ethnicity, nationality, PHI, Biometric Information (such as facial geometry), age, height, weight, eye color, hair color, information that you or your clinician enter when creating or updating your account, or that we receive about you from a third party, such as a lab or Healthcare Providers.

2.2 Aggregated Information

After stripping out any information that directly identifies you, or directly relates to you, from the Personal Information that we collect about you, we may combine that information with information we collect about other users (“Aggregated Information”).

2.3 Cookies and Pixel Tags

We may also use tools such as cookies and pixel tags to gather information about users of our Website. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. “Pixel Tags” (sometimes called "web beacons" or "clear gifs") are a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported.

2.4 Unique Device Identifiers

Like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.

2.5 User-Provided Information

We collect information that you provide directly to us when you engage in the following:

  • Request or schedule a product demonstration
  • Register for one or more of our newsletters
  • Engage with or participate in our services, products, or other offerings, including when you:
    • Register for an account through your Healthcare Provider
    • Complete a Donor Questionnaire
    • Register as an Intended Parent or complete an Intended Parent Questionnaire
    • Communicate with us via email, telephone, video conference, text message, or other methods
    • Communicate or engage with us on our social media accounts (e.g., Facebook, Instagram, LinkedIn, Twitter, Pinterest)
    • Inquire about, apply for, or initiate employment with EDC
    • Are working for EDC

We may correlate this information with other Personal Information we have about you. We collect e-mail lists and information related to marketing services. When you use the Website, you may be given the option to subscribe to or to be added to our subscription or e-mail list. Whether or not you select these option(s), your Personal Information may be shared with third parties consistent with this Privacy Policy. You may opt-out or unsubscribe from these e-mail lists.

2.6 Hardware; Browser; IP Address

We may collect information from your use of the Website including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name, through the use of Cookies, web beacons or other technologies. This information may include the following: your browser and mobile device type, operating system and name of your Internet service provider; web pages you visit on the Website; IP address, browser type, profile information, geo-location information; information about your interactions with e-mail messages, such as whether the messages were opened and the links clicked in those e-mails; and standard server log information. If you are using a mobile device, we may also receive your UDID, or another unique identifier, and mobile operating system.

2.7 Payment Processing Information

We only collect the payment information outlined in Section 2.1 above. We may also use a third party(ies) for payment processing. We do not want you to send us your credit card or bank account information by e-mail or other means except where requested as part of the checkout process. Please review the terms of use and privacy policies of the third-party payment processor prior to providing Personal Information to them.

2.8 Geolocation

If you access the Website through a desktop or mobile device, we will collect, monitor and/or remotely store geo-location data.

2.9 Third Parties

We may also obtain information from other sources and combine that with information we collect directly. For example:

  • To use our Services, you must have an account with a Healthcare Provider who also uses our Services. Your Healthcare Provider may provide us with additional Personal Information about you, including your contact information, preferences, and medical test results.
  • We may also collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, mailing list providers and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.
  • We use third-party services, such as Google Analytics, Google AdWords, Facebook Pixel, DoubleClick and Twitter Conversion Tracking, to track and analyze online behavior of our Users. These services may help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
  • When you interact with us through social media networks, such as when you follow us, share content or contact us through Facebook, Twitter, Instagram, YouTube, Snapchat or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question.

3. HOW WE USE YOUR INFORMATION

3.1 Personal Information

We may use your Personal Information for the following representative purposes:

  • To review and process your Donor Questionnaire or Intended Parent registration
  • If a Donor, your Personal Information will be used to create a Donor Profile, which is made available to your Clinic / Agency and Intended Parents.
  • If an Intended Parent, your Personal Information will be made avaialable to your clinic or agency.
  • To send communications and administrative e-mails to you
  • To satisfy our contractual obligations to you and provide the materials, goods and/or services that you request
  • To send you promotional/marketing information, newsletters, offers or other information
  • To perform internal operations, processing services, maintain user accounts, resolve disputes, establish, exercise, and defend legal claims, prevent and identify fraud, verify your identity and authenticate users
  • To personalize and tailor the features, performance and support of the Services
  • To analyze, benchmark and conduct research on user data and interactions with the Services
  • To identify your preferences, so we can notify you of new or additional products, services, contests, and/or promotions that might be of interest to you
  • To improve our services, content, programs, customer service, and overall user experience by aggregating and analyzing user data
  • To analyze the use of our products and services and information about users of the Services to enhance our marketing efforts
  • To communicate with you by e-mail, video conferencing, telephone, text message, app notifications, or other means about our company, our products, or other information that we believe may be of interest to you
  • To provide others with your Personal Information for the limited purposes described in this privacy policy
  • To send you notices of a transactional, administrative or relationship nature, or as required by law

3.2 Aggregated Information

We may use Aggregated Information for the following representative purposes in compliance with applicable law:

  • Perform internal operations on the Services
  • Improve the Website and customize the user experience
  • Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns
  • Allow third-party service providers such as Facebook, Google and Apple to retarget marketing and advertising to you through use of Cookies and Pixels
  • To train, fine-tune or otherwise improve our Models

3.3 Targeting

We may use Personal Information and Aggregated Information that we collect to target and measure the performance of advertisements to Users both on and off of the Website on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, Pixels, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Website; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.

4. LAWFUL PROCESSING; LEGITIMATE INTERESTS

Our processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:

  • Performing a contract with you, or to take steps at your request prior to contracting with you
  • Protecting your vital interests or the interests of another person
  • Complying with our legal obligations
  • Pursuing our legitimate interests, including without limitation:
    • Providing, improving and customizing our Website and Services;
    • Providing, improving and customizing our Website and Services;
    • Administration of our operations;
    • Maintaining our accreditation status and complying with all reporting obligations related thereto;
    • Maintaining an ongoing relationship with Healthcare Providers, donors and prospective donors, and helping to connect them with others;
    • Understanding how our Website and Services are being used;
    • Exploring ways to develop and grow our business;
    • Ensuring the safety and security of our employees and others;
    • Cybersecurity;
    • Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
    • Meeting our obligations and enforcing our legal rights

5. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

5.1 We will not rent, sell or share your Personal Information with third parties except as described herein. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Website or provide your Personal Information at any time. If you choose not to provide any Personal Information that is necessary for us to accept you into EDC programs or to provide you with specific products or services, we may not be able to provide those programs, products or services to you.

5.2 To use our Services, you must have an account with a Healthcare Provider who also uses the Services. Because of this, your use of our Services is also subject to your Healthcare Provider’s privacy policy by using our Services, Personal Information you provide or which is collected about you through your use of the Services will be disclosed to your Healthcare Provider.

5.3 We may disclose your Personal Information to outside individuals and/or companies that help us bring you the services and products we offer and to create, operate, and maintain our Website. For example, we may work with third parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; and (g) provide other services designed to assist us in developing and running our Website and/or Services and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.

5.4 We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

5.5 We may share Aggregated Information with third parties. We may share this information with others without express notice to you or consent from you, and we may, subject to applicable laws, exploit, use and disclose Aggregated Information without limitation of any kind. We may authorize certain service providers to utilize Aggregated Information for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.

6. USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGIES

6.1 The Website may use Cookies. Cookies help us remember you when you return to the Website. Cookies also hold information to personalize and enhance your experience and to gather Website statistical data, such as which pages are visited, the Internet provider's domain name and the addresses of the sites you visited immediately before coming to and immediately after leaving the Website. The information in the cookies lets us trace your "clickstream" activity (i.e., the paths taken by users of the Website as they move from page to page) to enable us to better serve you by revealing which portions of the Website are the most popular. We may also allow our affiliate and service providers and advertisers to serve cookies from the Website to allow them to assist us in various activities such as doing analysis and research on the effectiveness of the Website, its content and advertising. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies. For more information, see: www.networkadvertising.org.

6.2 We may also use Pixel Tags, which help us analyze users’ online behavior and measure the effectiveness of the Website and our advertising and marketing. Pixel Tags or Clear gif files are tiny graphics with a unique label that work in a similar way to cookies and are used to monitor the user’s online activities. In contrast to cookies that are saved on a user’s computer hard disk, clear gif files are embedded invisibly in websites and are about as big as the full stop at the end of this sentence. Where appropriate, we may combine the information collected by such Pixel Tags with the Personal Information of our customers. We may also use other analytical tools to evaluate site performance through the use of Aggregated Information, which contain no Personal Information. We work with service providers that help us track, collect, and analyze this information.

6.3 Cookies, Pixel Tags, and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies, pixel tags, and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.

6.4 We may combine the information collected through Cookies, Pixel Tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Website, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes. We may use and share aggregated and anonymous information to conduct market research and analysis for ourselves and/or for our business partners. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us. For more information about how to opt out of Cookies, refer to Section 9.

7. USE OF AI AND AUTOMATED TOOLS

    7.1 AI and Automated Processing

We use AI technologies, including those provided through Amazon Web Services and Microsoft Azure OpenAI, to provide four main features: (1) a facial analysis of Donors and Intended Parents to filter available Donors based on comparable facial features; (2) a search feature that suggests Donors with traits based on Intended Parents’ requests; (3) a chatbot for use by Clinicians to evaluate Donor Questionnaires; and (4) a tool that generates clarifying questions for Clinics to ask Donors. AI-generated content is provided for informational purposes only and should not be relied upon as the basis for any medical or reproductive decisions. To the extent Amazon Web Services’ Model(s) or Microsoft Azure OpenAI’s Model(s) are used in connection with a particular query, that model’s terms apply to you or your particular query (as applicable). Amazon Web Services’ terms of use are located here: https://aws.amazon.com/service-terms/ and its privacy policy is located here: https://aws.amazon.com/privacy/. Microsoft Azure’s terms of use are located here: https://www.microsoft.com/en-us/legal/terms-of-use and its privacy policy is located here: https://www.microsoft.com/en-us/privacy/privacystatement.

    7.2 Data Handling for AI Features

When you interact with our AI features, the information you provide (including queries and uploaded documents) may be processed by our AI systems. We implement commercially reasonable safeguards to protect your data during these processes. Any processing of data by AI is conducted within EDC’s controlled hosting environment, no component of such data processing is transferred to any third-party domain. Additionally, your Personal Information will not be used to train Models. However, Aggregated Information may be used to improve our Models.

    7.3 Limitations and User Responsibilities

AI-generated responses and search results are intended for reference only. Due to the nature of AI, AI Outputs may be incomplete or inaccurate. Users should not rely on AI-generated results to augment human decision-making and should consult qualified healthcare professionals prior to acting on any automated recommendations.

8. DATA RETENTION

8.1 We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.

8.2 Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.

8.3 Where we are processing Personal Information as set out in this policy, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 10).

8.4 Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

8.5 We will retain your Biometric Information (e.g., photograph) for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes, protect our legal rights, or otherwise to comply with legal obligations. EDC will permanently destroy any such Biometric Information in its possession no longer than the earlier of the date (i) that the initial purpose for collecting or obtaining such Biometric Information has been satisfied, or (ii) within 3 years of your last interaction with EDC.

9. OPTING OUT

9.1 Unsubscribe

You may opt out of: (a) receiving e-mail communications such as e-mail newsletters and promotional e-mails by following the instructions provided at the bottom of each e-mail, clicking the “unsubscribe” button at the bottom of e-mails we sent you; and/or (b) receiving promotional e-mail communications and newsletters by e-mailing us at unsubscribe@eggdonorconnect.com and including the word “UNSUBSCRIBE” in the subject line. Opting out of receiving Website communications will not affect your receipt of service-related, and administrative communications, such as payment confirmations, delivery status updates, updates to our Terms of Use and this Privacy Policy as we must be able to communicate with you regarding your purchases. If you do not receive a response from us to any e-mails you send to us within ten (10) business days, please send us another e-mail as your original e-mail may not have been received.

9.2 Google Analytics, Facebook, and Apple

Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display and retarget our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located at https://adssettings.google.com/authenticated. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located at https://tools.google.com/dlpage/gaoptout. We may also work with Facebook and Apple to provide analytics and advertising retargeting in connection with our Website, including our mobile applications.

For more information about Facebook’s privacy practices, visit https://www.facebook.com/about/privacy, and to opt-out you can visit https://www.facebook.com/help/568137493302217.

For Apple’s privacy policy, click here http://www.apple.com/privacy/privacy-policy/ and learn how to control what you share and opt-out of sharing here https://www.apple.com/privacy/control/.

9.3 Ad Industry Opt-Outs

You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/.

You may can opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/ or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/.

When using the ad industry opt out tools, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.

9.4 Cookies

You can opt out of accepting Cookies or disable them from your browser. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting Cookies or can disable them entirely. If you opt out of Cookies, you will not be able to take advantage of various features of the Website that are available to other users. For example, we may use Cookies to recognize you by name when you return to this Website so you don’t have to login again and provide your password each time.

10. BASIS FOR CONTINUED USE OF YOUR PERSONAL INFORMATION

Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.

11. NOTICE TO US STATE RESIDENTS

This section supplements the other sections of this Privacy Policy and applies to you only if you are a resident of California or another U.S. state that has passed a privacy law similar to the California Consumer Privacy Act (“CCPA”) that applies to us, and the law requires specific privacy notice disclosures.

11.1 Processing of Personal Information

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of Personal Information and Sensitive Personal Information about residents:

  • Identifiers, such as name, e-mail address and IP address
  • Personal information categories listed in the California Customer Records statute such as name, address and telephone number
  • Commercial information such as records of products or services purchased
  • Internet or other similar network activity such as Usage Data
  • Geolocation data such as IP address
  • Professional or employment-related information such as title of profession, employer, professional background and other information provided by you when you apply for a job with us
  • Non-public education information collected by certain federally funded institutions such as education records that you provide when you apply for a job with us
  • Account access credentials for the Services
  • Biometric Information, such as face photographs
  • Health information of Donors

The specific business or commercial purposes for which we have collected and disclosed your Personal Information and the categories of sources from which we collect your Personal Information are described in Section 3, titled How We Use Your Information. The third parties that we have disclosed your information to are described in Section 5, titled How We Share and Disclose Personal Information. We only use and disclose Sensitive Personal Information for the purposes specified in the CCPA or otherwise in line with the consent that you provide to your Clinic and to us when you create your account with EDC. The criteria we use to determine how long to retain your Personal Information are described in Section 8, titled Data Retention.

11.2 Selling and/or Sharing of Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA) Personal Information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

11.3 California Account Holders Under 18

Any California residents under the age of eighteen (18) who have registered to use the Services and who have posted content or information available to others on the Services can request that such information be removed from the Services by contacting us at the e-mail address set forth in Section 18, titled Contact Us. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

11.4 Shine the Light

Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. EDC does not share Personal Information with third parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at contact us via e-mail at legal@eggdonorconnect.com or write to us at Egg Donor Connect, LLC, Attn: Privacy Office, 8 Aurora Ave., Saratoga Springs, NY 12866. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.

11.5 Additional California Resident Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us once each calendar year to ask if you have shared Personal Information with third parties for their direct marketing purposes or may contact us at any time to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes. We do not currently disclose any of your Personal Information to third parties for their direct marketing purposes.

California residents may exercise the following rights by contacting us by phone at the toll-free phone number (833) 914-1336 or by e-mail at legal@eggdonorconnect.com, or as described at the end of this document:

  • Know the ways in which we acquire, use, share, disclose and otherwise process your Personal Information;
  • Know the specific pieces of your Personal Information that we hold;
  • Request the deletion of your Personal Information, subject to several exceptions; and
  • Not to be denied goods or services for exercising these rights.

11.6 Nevada Residents

If you are a resident of the State of Nevada, you have the right to opt out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not sell your Personal Information at all, including as defined in the Nevada Revised Statutes Chapter 603A.

11.7 Your Rights and Privacy Choices

Certain U.S. state laws (including but not limited to the states listed below) provide residents with the right to opt out of the “sale” or “sharing” of their Personal Information, including through the use of third-party cookies and tracking technologies used for cross-site behavioral advertising or similar purposes.

  • California (California Consumer Privacy Act - CCPA / California Privacy Rights Act - CPRA)
  • Colorado (Colorado Privacy Act - CPA)
  • Connecticut (Connecticut Data Privacy Act - CTDPA)
  • Delaware (Delaware Personal Data Privacy Act – DPDPA)
  • Florida (Florida Digital Bill of Rights - FDBR)
  • Montana (Montana Consumer Data Privacy Act - MTCDPA)
  • New Jersey (New Jersey Data Privacy Act - NJDPA)
  • Oregon (Oregon Consumer Privacy Act - OCPA)
  • Texas (Texas Data Privacy and Security Act - TDPSA)
  • Utah (Utah Consumer Privacy Act - UCPA)
  • Virginia (Virginia Consumer Data Protection Act - VCDPA)

These laws define “sale” and “sharing” broadly, including certain data exchanges for targeted advertising.

11.8 How to Opt-Out

These laws allow you to opt out of the sale or sharing of your Personal Information with third parties for purposes such as cross-context behavioral advertising. If you are accessing this Website or the Services from one of the states listed above or an eligible state not listed above, you may email us at legal@eggdonorconnect.com with the subject line “Opt-Out” and direct us to stop the sale or sharing of your Personal Information, including for targeted advertising purposes, as defined by applicable state laws.

Important Note: If you are not a resident of an eligible state, you may not be eligible to exercise these specific opt-out rights. However, we are committed to respecting your privacy preferences and encourage you to review the rest of this Privacy Policy for more information about your choices. This opt-out applies only to the browser and device you’re currently using. For broader coverage, you may also use a browser that supports Global Privacy Control (GPC), which we recognize where required

11.9 Consumer Health Data

If you are a resident of Washington, Nevada, Connecticut, or any other state with consumer health privacy laws, please refer to our Consumer Health Data Privacy Policy to learn how EDC handles your Consumer Health Data.

11.10 Non-Discrimination.

We will not discriminate against you for exercising any of your rights under applicable state law, including:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

11.11 Do Not Track

Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" requests or signals at this time.

12. DATA HOSTING AND TRANSFERS

We may host and process data using leading cloud infrastructure providers, such as Amazon Web Services (AWS), Microsoft Azure and/or Google Cloud Platform (GCP), with data centers primarily located in the United States. These providers are contractually obligated to implement appropriate technical and organizational safeguards and may only process Personal Information on our behalf and in accordance with policies consistent with this Privacy Policy.

13. CHILDREN

This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at contact us via e-mail at legal@eggdonorconnect.com or write to us at Egg Donor Connect, LLC, Attn: Privacy Office, Egg Donor Connect, 8 Aurora Ave, Saratoga Springs, NY 12866 so that we may delete and remove such information from our system.

14. SECURITY

We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.

15. THIRD-PARTY WEBSITES AND SERVICES

While visiting the Website or using the Services, you may link to websites or services operated by third parties or you may have come to the Website or Services using a link found in another website or service. Moreover, the Website contains links to and/or enables certain third-party functionalities to enhance your experience on the Website, including social plug-ins, tools and APIs. We do not make any representations or warranties about any third-party website or service, and we have no control over them or the information, services, or products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites or through its services, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website's privacy policy before providing Personal Information; your communications and interactions with such third parties in respect of their own processing of your Personal Information are solely between you and them and are at your own risk.

16. CHANGES TO OUR PRIVACY POLICY

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.

17. DATA LOCATION

We store data in U.S. data centers.

18. CONTACT US

If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at legal@eggdonorconnect.com or write to us at Egg Donor Connect, LLC, Attn: Privacy Office, 8 Aurora Ave, Saratoga Springs, NY 12866.