Consumer Health Data Privacy Policy

This policy supplements our Privacy Policy and explains how Ivy Surrogacy handles consumer health data — information about your physical or reproductive health — as that term is used in the Washington My Health My Data Act, Nevada Senate Bill 370, and similar laws. We apply it to everyone who uses our website or portal, wherever you live.

Ivy Surrogacy is a surrogacy and egg donation agency. We are not a medical provider and not a HIPAA covered entity. We collect health-related information for one reason: to evaluate whether you can safely take part in a surrogacy or donation journey and to coordinate that journey with the clinics and attorneys involved.

1. Consumer health data we collect

Depending on which service you apply for, we may collect:

Reproductive and pregnancy history: number of prior births and pregnancies, C-sections, pregnancy complications, breastfeeding status, menstrual and contraception details, and for intended parents, IVF clinic and embryo details (including PGT-A results and whether an egg or sperm donor is used), whether you already have children, and your family-building preferences.
Body measurements: height, weight, and the resulting BMI.
Lifestyle and substance use: smoking, vaping, alcohol, and recreational drug use.
Medical background: conditions, medications and allergies, surgeries, mental-health history, family medical history, and, for intended parents, infectious-disease screening results for you and your partner (for example HIV, hepatitis B and C, syphilis, gonorrhea, and chlamydia), plus health-related documents, records, and photographs you upload.
Age and citizenship or residency status as part of program eligibility.
Pre-screening answers: the six eligibility questions on our surrogate landing page (age, prior births, C-sections, BMI, substance use, residency). If you are not eligible, we keep only an anonymous daily count of which question stopped you; that count contains no name, email address, IP address, or cookie. If you are eligible and go on to apply, your answers about prior births, C-sections, height, weight, and BMI are saved with your application.
Chat assistant messages: anything you choose to type into our website chat assistant. Please do not enter medical details there.

We do not collect precise geolocation. We use your IP address to determine your country and, in the United States, your state, so that we can apply the consent rules that govern your location; this location value is kept in a cookie for 24 hours and is not stored with your application. Like any website, we also receive your IP address with every request and use it for security and bot protection (Cloudflare), rate limiting, and short-lived server logs; it is stored with website chat-assistant sessions, and — only if you have accepted cookies — it is included in the ad-measurement events described at the end of Section 4.

2. Where the data comes from

You — through our application forms, the surrogate pre-screening questionnaire, your portal account, the chat assistant, email, phone, and text messages, and through lead forms you fill in on our advertisements on Meta (Facebook and Instagram) or on job boards, which pass your answers on to us.
IVF clinics, physicians, psychologists, and attorneys involved in your journey, with your authorization.
Intended parents, surrogates, or donors you are matched with, to the extent they share information relevant to the shared journey.

3. Why we collect it

To evaluate your eligibility for our surrogate, egg donor, sperm donor, or intended parent programs.
To match intended parents with surrogates and donors.
To coordinate medical screening, treatment, legal contracts, escrow, and insurance with the professionals involved in your case.
To communicate with you about your application, appointments, and journey.
To keep the records that applicable law requires us to keep.
To improve our recruiting pages using anonymous, aggregated pre-screening counts.

We collect consumer health data only to provide the service you have asked us for. We do not collect it for any other purpose, and we do not use it for advertising.

4. Who we share it with

We share the categories of consumer health data listed in Section 1 — and only the parts each recipient needs for its role — with:

IVF clinics and healthcare providers conducting your medical screening, treatment, or prenatal care.
Reproductive attorneys preparing and reviewing the legal agreements for your journey.
Escrow, insurance, and electronic-signature providers when they are part of your case, limited to what they need.
Referral partners (ambassadors): if you were referred by one of our ambassadors, that ambassador can see your name, the contact details on the referral, and the stage your application has reached (in progress, applied, approved, matched, or closed) so that we can pay their referral reward. They never see your questionnaire answers or medical information.
The intended parents, surrogate, or donor you are matched with, limited to the information needed to make and carry out the match, and as agreed in your journey.
Service providers who work for us under contracts that restrict them to our instructions: cloud hosting and storage, email and text-message delivery, document e-signature, and IT support.
AI assistant providers (Anthropic and Google), only for messages you type into the website chat assistant, and only to generate a reply.
Government authorities when the law or a valid legal process requires it.

We do not sell consumer health data. We do not share it with affiliates (we have none that receive it). We do not share it with advertising platforms: the analytics and ad-measurement tools on our website (Google Analytics, and the Meta Pixel, which loads only after you accept cookies) receive page views and generic progress events (including that a visitor passed or did not pass the pre-screening questionnaire, but never which question or why) and never your pre-screening answers or your health details. If you have accepted cookies and then submit a form, Meta also receives a one-way hashed email address, your IP address and browser type, Meta's cookie identifiers, an internal reference number, which program you applied to, and, for surrogate applications, a hashed version of your state — used only so we can measure whether an advertisement led to that application (Section 7 of our Privacy Policy). No third party collects consumer health data about you through our website over time or across other websites.

5. Consent

You provide your health information to us voluntarily when you apply. We collect it, and share it with the parties listed in Section 4, because that is necessary to provide the surrogacy or donation service you have asked us for; the law allows collection and sharing on that basis. Where consent is required instead — for example before we use or share your data for any purpose that your journey does not require — we ask for it separately and specifically, in words that say what would be shared, with whom, and why. We never treat your reading of this policy, or your acceptance of our terms, as that consent. Ad measurement (see the end of Section 4) is a separate choice you make on the cookie banner and can withdraw at any time.

You can withdraw any consent, and ask us to stop collecting or sharing your consumer health data, at any time by contacting us (Section 7). Withdrawing stops future collection and sharing; it does not undo sharing that already happened, and it may mean we can no longer provide the service.

6. Your rights

You have the right to:

Confirm whether we are collecting, sharing, or selling your consumer health data, and access that data.
Review and correct it: email us (Section 7) with the change you need and we will update our records.
Receive a list of the third parties and affiliates with whom we have shared your consumer health data, together with an email address or other way to contact each of them.
Withdraw consent to our collecting or sharing it.
Delete your consumer health data. Within 30 days of verifying your identity we delete it from our systems and notify the third parties we shared it with so they can delete it too, subject to the record-keeping rules in Section 11 of our Privacy Policy (for example, case files that the law requires us to keep are retained with your identifying details removed wherever possible). Copies in our encrypted backups can persist for up to 13 months; backups are used only for disaster recovery, and if one is ever restored we re-apply the deletion immediately.
Not be discriminated against for exercising these rights.

We do not use geofencing around any facility that provides health care services.

7. How to exercise your rights

Email contact@ivysurrogacy.com with the subject line "Health Data Request", or call (626) 545-1617.
Portal account holders can delete their account directly from Settings → Delete Account.

We will respond within 45 days of receiving your request; if we need more time, we will tell you why within those 45 days and take up to 45 additional days. Deletion requests are completed, and the third parties we shared with are notified, within 30 days of verifying your identity. We may ask you to verify your identity before acting on a request, and we will not charge you for a request unless it is manifestly unfounded or excessive.

Appeals: if we deny your request, you may appeal by replying to our decision within a reasonable time, and we will respond in writing within 45 days. If you are not satisfied with the outcome, you may complain to your state attorney general — Washington: atg.wa.gov/file-complaint; Nevada: Office of the Nevada Attorney General, ag.nv.gov (File a Complaint), 100 North Carson Street, Carson City, NV 89701, (775) 684-1100; other states: your attorney general's consumer protection office.

8. Security and retention

The safeguards and retention periods in Sections 8 and 11 of our Privacy Policy apply to consumer health data. Anonymous pre-screening counts contain no personal information and are kept indefinitely.

9. Contact

📧 Email: contact@ivysurrogacy.com
📞 Phone: (626) 545-1617
📍 Ivy Surrogacy, Los Angeles, California, USA

10. Changes to this policy

If we materially change how we collect or share consumer health data, we will post the updated policy here with a new effective date before the change takes effect, and we will not apply a new category or purpose to data we already hold without first asking for your consent.