Privacy Policy

Tandem Privacy Policy

Last updated: December 15, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

Because We operate as a surrogacy agency, We understand that We may process extremely sensitive information about Your reproductive health, fertility, pregnancy, medical treatment, and family-building plans. This Policy also explains, in plain language, how We safeguard that information and the special protections that may apply to reproductive and health information.

We use Your Personal Data to provide and improve the Service and to operate our surrogacy programs. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Business, for the purpose of the CCPA and CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Tandem Surrogacy LLC, 50 W Broadway Ste 333 PMB 568177 Salt Lake City, Utah 84101-2027.
  

• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website.
• Country refers to: California, United States.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual.
• Sensitive Personal Information, for the purposes of the CPRA, includes certain categories of Personal Data that are considered more sensitive, such as precise geolocation, account log-in credentials, and information concerning a person’s health, sex life, or sexual orientation.
• Health Information means information related to Your past, present, or future physical or mental health or condition, fertility, reproductive health, pregnancy, medical care, or genetic information.
• Protected Health Information (PHI) has the meaning given to it under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and related regulations. PHI generally includes individually identifiable health information that is transmitted or maintained in any form or medium by a covered entity or its business associate.
• Sale or Sell, for the purpose of the CCPA/CPRA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Website and any related online services We provide.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• Website refers to Tandem Surrogacy LLC, accessible from https://tandemsurrogacy.com.
• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service or participating in Our surrogacy programs, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Preferred contact methods and communication preferences

Health and Reproductive Information

In connection with Our surrogacy services, We may also collect and process Health Information and other sensitive details related to You, including but not limited to:

• Medical and reproductive history (e.g., past pregnancies, miscarriages, fertility diagnoses or treatments)
• Information about fertility evaluations, IVF cycles, embryo transfers, medications, and treatment plans
• Laboratory and diagnostic test results, including genetic or carrier screening results (where applicable)
• Psychological or mental-health evaluation records, if You choose to participate in such evaluations as part of Our program
• Information regarding embryos, eggs, sperm, donors, and related clinical notes (to the extent provided to or accessed by Us)
• Insurance information, claim information, and billing information related to fertility, obstetric, or related healthcare services
• Information about Your pregnancy progression, prenatal care, delivery, and post-pregnancy follow-up, if You are a gestational carrier
  
  

Some of this information may be treated as Protected Health Information (PHI) when We receive it from, or process it on behalf of, a HIPAA-covered health care provider or health plan. In those cases, Our use and disclosure of PHI is governed by HIPAA and any applicable Business Associate Agreement, in addition to this Privacy Policy.

Information About Minors and Resulting Children

As part of a surrogacy arrangement, We may maintain records that include information about the child or children born from the arrangement (for example, basic identifying information, birth details, and relevant legal documentation). We treat this information as highly sensitive and use it only as necessary to fulfill Our contractual and legal obligations and to support the intended parents and gestational carriers, consistent with applicable law.

We do not knowingly allow children under the age of 18 to create accounts on Our Website or submit information directly through the Service.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include:

• Your Device’s IP address
• Browser type and version
• Pages visited, time and date of Your visit, time spent on pages
• Unique device identifiers and other diagnostic data
  
  

When You access the Service by or through a mobile device, We may collect similar information about Your device and usage.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies (beacons, tags, scripts) to track activity on Our Service and store certain information. You can control Cookies through Your browser settings, but refusing Cookies may impact Your ability to use some portions of the Service.

We use:

• Necessary / Essential Cookies

• Cookie Policy / Notice Acceptance Cookies

• Functionality Cookies

For more information about the Cookies We use and Your choices, please refer to the Cookies section of this Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data, Health Information, and PHI (where applicable) for the following purposes:

• To provide and maintain our Service
  Including monitoring usage and ensuring the Website and associated systems function properly.
• To operate our surrogacy and family-building programs
  Including:
  • Assessing eligibility of intended parents and gestational carriers
  • Coordinating with fertility clinics, labs, mental health professionals, attorneys, escrow/financial institutions, brokers, and insurers
  • Facilitating communications between intended parents, gestational carriers, and other involved professionals
  • Supporting case management, record-keeping, and quality assurance
• To manage Your Account
  Including registration as a user and providing access to specific functionalities.
• For the performance of a contract
  Including surrogacy agreements, service agreements with intended parents, gestational carriers, or other clients.
• To contact You
  By email, phone, SMS, or other electronic communication regarding updates, case-related information, and security notices.
• To provide You with news and information
  About Our services, educational materials, support resources, and events similar to those You have already engaged with, unless You opt out.
• To manage Your requests
  Including responding to questions, case-related inquiries, and privacy requests.
• For internal business purposes
  Such as:
  • Data analysis, quality improvement, and program evaluation
  • Training, auditing, and compliance
  • Developing new services and improving user experiences
• For business transfers
  To evaluate or conduct a merger or similar transaction, as described further below.
• For compliance and legal purposes
  Including:
  • Complying with applicable laws and reporting obligations
  • Responding to subpoenas, court orders, or other lawful processes
  • Managing legal claims and regulatory inquiries

Important Limitation on Advertising and Sale

We recognize the sensitive nature of the data We process, especially Health Information and reproductive information. We do not use your Health Information, PHI, or reproductive information for targeted advertising or for creating marketing profiles unrelated to the surrogacy services we provide.

We also do not sell your Personal Data, including your Sensitive Personal Information, and we do not share it for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

Sharing of Your Personal Data

We may share Your personal information in the following situations, always subject to applicable law and, where relevant, HIPAA/health-privacy requirements:

• With Service Providers
  To monitor and analyze the use of our Service, provide IT and hosting services, communications tools, or customer support.
• With Healthcare Providers and Clinics
  With Your consent or as otherwise permitted by law, We may share necessary information with fertility clinics, labs, OB/GYNs, mental health professionals, and other healthcare providers to support Your surrogacy journey.
• With Legal Counsel and Other Professional Advisors
  As needed to coordinate legal services related to surrogacy, parental rights, and related matters, and to obtain professional advice (e.g., accountants, auditors, compliance consultants).
• With Financial, Escrow, and Insurance Service Providers
  To facilitate payments, manage escrow accounts, process insurance coverage and claims, and comply with financial/legal obligations.
• For Business Transfers
  We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company, subject to appropriate confidentiality and data-protection commitments.
• With Affiliates
  We may share Your information with Our affiliates, provided they honor this Privacy Policy or equivalent protections.
• With Your Consent
  We may disclose Your personal information for any other purpose with Your explicit consent.
  
  

We do not sell Personal Data and do not share Personal Data for cross-context behavioral advertising.

Retention of Your Personal Data

The Company will retain Your Personal Data and Health Information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, including:

• Providing surrogacy and related services
• Complying with legal, regulatory, and professional recordkeeping requirements
• Managing actual or potential disputes and claims
  
  

In general:

• Surrogacy case files (including relevant Personal Data and Health Information) may be retained for a period consistent with applicable statutes of limitation, medical record retention laws (where applicable), and professional standards.
• Billing, insurance, and financial records may be retained for the period required by tax, accounting, and financial regulations.
• Usage Data is typically kept for a shorter period, unless it is needed for security, compliance, or improvements to the Service.
  
  

When data is no longer needed for these purposes, We will either delete it or de-identify it in accordance with applicable law and Our data-retention policies.

Transfer of Your Personal Data

Your information, including Personal Data and Health Information, may be processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This may involve transferring Your information to jurisdictions with different data protection laws than those in Your jurisdiction.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and applicable law, including, where required, using appropriate contractual and technical safeguards for international data transfers.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy, to the extent required by law.

Law Enforcement and Legal Requests

Under certain circumstances, the Company may be required to disclose Your Personal Data or Health Information if required to do so by law or in response to valid requests by public authorities (e.g., a court, law-enforcement agency, or regulatory authority).

We will review any such request carefully and respond only as required or permitted by applicable law, taking into account any special protections that may apply to reproductive health information, medical records, or PHI. Where allowed, We may seek to narrow the scope of such requests and to notify affected individuals.

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service or Our surrogacy programs
• Protect the personal safety of Users of the Service, gestational carriers, intended parents, children, or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data and Health Information is important to Us. We use commercially reasonable technical, administrative, and physical safeguards designed to protect Your data from unauthorized access, use, or disclosure.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to protect Your Personal Data, We cannot guarantee its absolute security.

HIPAA and Health Privacy Laws

In some situations, We may act as a “business associate” under HIPAA, processing PHI on behalf of a HIPAA-covered healthcare provider or health plan. In those cases:

• Our use and disclosure of PHI is governed by our Business Associate Agreement and HIPAA; and
• If there is a conflict between this Privacy Policy and HIPAA or Our Business Associate Agreement, HIPAA and the Business Associate Agreement will control with respect to PHI.
  
  

When We collect Health Information directly from You outside of a HIPAA-covered relationship (for example, via Website forms or direct communications), that information may not be PHI but will still be treated as highly sensitive and handled in accordance with this Privacy Policy and applicable state and federal laws (including reproductive health privacy laws where applicable).

Reproductive Health and Safety

We recognize that information about Your reproductive health, fertility, pregnancy, and family-building plans is extremely sensitive. Accordingly:

• We do not use such information for targeted advertising or for marketing unrelated to Our surrogacy and family-building services.
• We do not sell or share such information for cross-context behavioral advertising.
• We will not voluntarily disclose reproductive health information to law enforcement or other third parties except:
  • As required by applicable law or court order, or
  • To protect the safety of a person or child, or to prevent serious harm, in circumstances allowed by law.
    
    

We will evaluate any request for reproductive health information with particular care, including applicable federal, state, and local protections, and We will seek to limit disclosures to the minimum necessary.

CCPA/CPRA Privacy Notice (California Residents)

This section supplements the information contained elsewhere in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We may collect the categories of personal information described in your original policy (Identifiers, Customer Records, Internet Activity, etc.), and, in some cases, Sensitive Personal Information, such as:

• Health and reproductive information
• Information concerning sex life, sexual orientation, or pregnancy
• Account log-in information if combined with a password or similar credentials
  
  

We collect these categories for the purposes described above in “Use of Your Personal Data” and “Health and Reproductive Information.”

No Sale or Sharing of Personal Information

We do not sell Personal Information, including Sensitive Personal Information, and We do not share Personal Information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

If Our practices change in the future, We will update this Privacy Policy and, where required, provide appropriate notices and opt-out mechanisms.

Use and Disclosure of Sensitive Personal Information

To the extent We collect or process Sensitive Personal Information (such as Health Information, reproductive information, or account credentials), We use it only for limited purposes permitted under the CPRA, such as:

• Providing the services reasonably expected by You
• Performing services on behalf of the business
• Ensuring security and integrity
• Short-term, transient use (where applicable)
• Legal and compliance purposes
  
  

We do not use Sensitive Personal Information to infer characteristics about You for unrelated marketing or profiling.

Your Rights Under CCPA/CPRA

If You are a California resident, You may have the rights to:

• Right to Know / Access – Request that We disclose what Personal Information We collect, use, disclose, and maintain about You.
• Right to Delete – Request deletion of Personal Information We hold about You, subject to certain legal exceptions.
• Right to Correct – Request correction of inaccurate Personal Information.
• Right to Limit Use of Sensitive Personal Information – Where applicable, request that We limit Our use or disclosure of Sensitive Personal Information to certain allowed purposes.
• Right to Non-Discrimination – Not be discriminated against for exercising any of Your CCPA/CPRA rights.
  
  

Because We do not sell or share Personal Information, the Right to Opt Out of Sale or Sharing is not currently applicable to Our practices. If that changes, We will update this Policy and provide appropriate mechanisms.

Exercising Your CCPA/CPRA Data Protection Rights

To exercise any of these rights, if You are a California resident, You can contact Us:

• By mail:
  Tandem Surrogacy
  50 W Broadway Ste 333
  PMB 568177
  Salt Lake City, UT 84101-2027
  
  

Your request must:

• Provide sufficient information to allow Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative; and
• Describe Your request with sufficient detail.