Novaparent Surrogacy is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed in connection with our website and surrogacy coordination services.
This Privacy Policy applies to www.novaparent-surrogacy.com (our "Service"). By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.
1. Definitions and Key Terms
To help explain things as clearly as possible, every time any of these terms are referenced, they are strictly defined as:
- Cookie: small amount of data generated by a website and saved by your web browser. Used to identify your browser, provide analytics, and remember information such as your language preference.
- Company: when this policy mentions "Company," "we," "us," or "our," it refers to Private Entrepreneur Andrii Khodonovych, registered in Ukraine, with office at Lukyanivska 69/71, Kyiv. Registration No. 2659202114310 (registered 21.09.2020).
- Country: Ukraine — where Novaparent Surrogacy is registered and operates from.
- Customer: refers to a person or married couple engaging Novaparent Surrogacy for surrogacy coordination services.
- Device: any internet-connected device such as a phone, tablet, computer, or any other device that can be used to visit Novaparent Surrogacy and use our services.
- IP address: Every device connected to the Internet is assigned a number known as an Internet Protocol (IP) address. These numbers are usually assigned in geographic blocks and can often be used to identify the general location from which a device connects to the Internet.
- Personnel: refers to those individuals who are employed by Novaparent Surrogacy or are under contract to perform a service on our behalf.
- Personal Data: any information that directly, indirectly, or in combination with other information allows for the identification or identifiability of a natural person.
- Sensitive Data: personal data revealing health, marital status, genetic information, or biometric data — which is given enhanced protection under GDPR Article 9 and Ukrainian Personal Data Law.
- Service: refers to the surrogacy coordination service provided by Novaparent Surrogacy as described on this platform and in individual program agreements.
- Third-party service: refers to medical clinics, legal counsel, accommodation providers, and other partners providing services as part of our coordination programs.
- Website: Novaparent Surrogacy's site, accessible at https://www.novaparent-surrogacy.com
- You: a person or entity that is using or engaging Novaparent Surrogacy's Services.
2. What Information Do We Collect?
We collect information from you when you visit our website, contact us through our forms, request a consultation, subscribe to communications, or engage our surrogacy coordination services.
Standard contact information:
- Name and surname
- Email address
- Phone number
- Country of residence
- Approximate age range
Sensitive personal data (collected only after you formally engage our services and sign a program agreement, and only with your explicit consent — required under GDPR Article 9):
- Marital status documentation
- Medical history and reproductive health information
- Genetic testing results (PGD, PGT-A) where applicable
- Documentation required for legal contracts in destination country
We collect sensitive data only to the extent necessary for surrogacy coordination, and we apply enhanced security and access controls to such data.
3. How Do We Use the Information We Collect?
Any information we collect from you may be used in the following ways:
- To respond to your consultation request and inquiries
- To coordinate your surrogacy program in Ukraine, Georgia, or Armenia
- To facilitate communication with partner clinics, legal counsel, and accommodation providers in your destination country
- To prepare legal documents required for the surrogacy program
- To improve our website and services based on your feedback
- To send periodic updates relevant to your program (with your consent)
- To comply with legal obligations under Ukrainian and applicable international law
4. Legal Basis for Processing (GDPR)
Where GDPR applies, we process your personal data on the following lawful bases:
- Consent — when you submit a contact form or sign a program agreement
- Contract performance — to deliver the services you have engaged us for
- Legal obligation — where required by Ukrainian law, GDPR, or destination-country law
- Legitimate interest — to improve our services and respond to inquiries
- Explicit consent (Article 9) — for processing sensitive data such as health information
5. When Do We Use Information from Third Parties?
We collect information you voluntarily provide to us. We may also receive limited information about you from:
- Partner clinics, legal counsel, or accommodation providers — only as part of coordinating your program
- Publicly available sources (e.g., professional information you have made public)
- Fraud-detection services that protect both you and us during initial contact
6. Do We Share the Information We Collect with Third Parties?
We share personal information only with parties who provide services within your program, and only to the extent necessary to deliver those services. Specifically:
- Partner medical clinics in Kyiv, Lviv, Tbilisi, or Yerevan — for medical assessment and IVF/embryo transfer
- Legal counsel — for surrogacy contracts and birth-certificate processing in your destination country
- Accommodation providers — for your stay during embryo transfer or birth
- Service providers we engage for hosting, email, and customer service — under strict data-processing agreements
- Government or law-enforcement officials — only when legally required, in response to valid legal process
We do not sell your personal data. We do not share your information with advertisers, marketing partners, or for marketing purposes unrelated to your program.
7. Cross-Border Data Transfers
Novaparent Surrogacy is registered in Ukraine. To deliver our services to international clients, your personal data may be transferred between:
- Ukraine (our registration and primary office)
- Georgia or Armenia (when your program is in one of these countries)
- EU/EEA (where most of our clients reside)
- Other countries where partner service providers operate
Where data is transferred from the EU/EEA to Ukraine or other non-adequacy countries, we rely on appropriate safeguards under GDPR Article 46, including Standard Contractual Clauses (SCCs) with our service providers.
To the fullest extent allowed by applicable law, by using our services and providing your data, you consent to such cross-border transfer for the purposes described in this policy.
8. How Do We Use Your Email Address?
By submitting your email address, you agree to receive responses from us regarding your inquiry or program. We may also send periodic updates relevant to your program (only with your consent). You can withdraw consent for non-essential emails at any time using the unsubscribe link in our emails or by contacting us directly.
We do not send unsolicited commercial emails. We do not use your email for advertising audience targeting on social media platforms.
9. How Long Do We Keep Your Information?
We retain your personal data only as long as necessary to fulfill the purposes described in this policy, and to comply with our legal and regulatory obligations:
- Inquiry data (consultation requests that did not lead to a program): up to 12 months
- Active program data: for the duration of the program plus 2 years for follow-up support
- Contractual and legal records: 7 years from the end of the program (Ukrainian law requirement)
- Tax and accounting records: 5 years from the end of the relevant tax year (Ukrainian law)
When we no longer need your information and there is no legal obligation to retain it, we will either remove it from our systems or anonymize it so you can no longer be identified.
10. How Do We Protect Your Information?
We implement reasonable technical and organizational security measures to protect your personal information, including:
- SSL/TLS encryption for all website traffic
- Restricted access to sensitive data on a need-to-know basis
- Encrypted storage of program-related documents
- Regular security reviews of our website infrastructure
While we use reasonable efforts to protect your personal information, no system is completely secure. We cannot guarantee the absolute security of any information you transmit to us.
11. Your Rights Under GDPR and Ukrainian Personal Data Law
If you are located in the EU/EEA, UK, or Ukraine, you have the following rights regarding your personal data:
- Right to access — request a copy of the personal data we hold about you
- Right to rectification — request correction of inaccurate or incomplete data
- Right to erasure ("right to be forgotten") — request deletion of your data, subject to legal retention requirements
- Right to restriction of processing — request that we limit how we use your data
- Right to data portability — receive your data in a structured, machine-readable format
- Right to object — object to processing based on legitimate interest
- Right to withdraw consent — withdraw consent for processing at any time, without affecting prior lawful processing
- Right to lodge a complaint — with your local data protection authority (in Ukraine: Ombudsman for Personal Data Protection)
To exercise any of these rights, please contact us at email loading…. We will respond within 30 days as required by GDPR.
12. Personnel
If you are a Novaparent Surrogacy worker or applicant, we collect information you voluntarily provide. We use this information for human-resources purposes — administering benefits, screening applicants, and conducting business operations.
13. Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger, or other transfer of all or substantially all of the assets of Novaparent Surrogacy, provided that the third party agrees to adhere to the terms of this Privacy Policy.
14. Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. "Corporate Affiliate" means any person or entity that directly or indirectly controls, is controlled by, or is under common control with Novaparent Surrogacy. Any information shared with our Corporate Affiliates will be treated in accordance with this Privacy Policy.
15. Governing Law
This Privacy Policy is governed by the laws of Ukraine, without regard to its conflict-of-laws provisions. You consent to the exclusive jurisdiction of the courts of Kyiv, Ukraine in connection with any action or dispute arising under this Privacy Policy.
Where you are an EU/EEA resident, the EU General Data Protection Regulation (GDPR) provides additional rights and protections, which are recognized and respected by Novaparent Surrogacy as described in Section 11.
16. Your Consent
By using our website, contacting us, or engaging our services, you hereby consent to this Privacy Policy and agree to its terms. If you do not agree, please do not use our website or services.
17. Links to Other Websites
This Privacy Policy applies only to our Services. Our website may contain links to other websites not operated by Novaparent Surrogacy. We are not responsible for the content or privacy practices of such websites. When you leave our website by following a link, our Privacy Policy is no longer in effect. Your interaction on any other website is subject to that site's own rules and policies.
18. Cookies
Novaparent Surrogacy uses essential cookies and local browser storage to provide a functional website. We use cookies to:
- Remember your cookie consent preference
- Identify general areas of the website you have visited (for analytics)
We do not place Personally Identifiable Information in cookies. For full details, see our Cookie Policy.
You may set your browser to block cookies, but this may impair some website functionality.
19. Tracking Technologies
Our website uses or plans to use the following tracking technologies:
- Cookies (essential): for cookie consent preference and basic functionality.
- Local Storage / Session Storage: for storing your cookie preference and improving page load on return visits.
- Google Fonts: we use Google Fonts (Cormorant Garamond and DM Sans) loaded from Google's CDN. Google may receive your IP address as part of font requests.
- Microsoft Clarity (planned): heatmap and session-recording analytics service. When activated, it will help us understand user navigation. Sessions may be recorded but will be anonymized.
- Cloudflare CDN (planned): content delivery and DDoS protection. Cloudflare may process IP addresses and request metadata.
- Cloudflare Turnstile (planned): privacy-respecting CAPTCHA alternative for our contact form, replacing Google reCAPTCHA.
- Form-handling service (planned): for processing your contact form submissions.
We do not use: advertising pixels, social media tracking pixels, third-party advertising networks, retargeting/remarketing, Google Analytics, or Tag Manager.
20. Kids' Privacy
Our services are intended for adults 18 years and older. We do not knowingly collect personal information from anyone under the age of 16. If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under 16 without verification of parental consent, we will take steps to remove that information.
21. Changes To Our Privacy Policy
We may change our Service and policies, and we may need to update this Privacy Policy to accurately reflect such changes. Unless otherwise required by law, we will notify you (for example, through our Service or via email) before making material changes. Continued use of the Service after changes take effect means you accept those changes. If you do not agree, you should stop using the Service and contact us regarding deletion of your data.
22. Third-Party Services
We may display, include, or make available third-party content (including data, information, or links). You acknowledge and agree that Novaparent Surrogacy is not responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect. Third-Party Services are provided as a convenience and you access them at your own risk and subject to those third parties' terms.
23. Information About GDPR (EU/EEA Residents)
If you are located in the European Economic Area (EEA) or United Kingdom, the General Data Protection Regulation (GDPR) gives you specific rights regarding your personal data. We respect these rights and comply with GDPR for all our processing activities.
The GDPR applies to any company globally — not just EU-based — that processes data of EU residents. Our customers' data is important regardless of where they are located, which is why we apply GDPR controls as our baseline standard for all operations worldwide.
24. What Is Personal Data Under GDPR?
Personal data is any information relating to an identified or identifiable person. GDPR covers a broad spectrum of information that could be used alone, or in combination with other pieces, to identify a person. Examples include name, email address, IP address, financial information, marital status, genetic data, biometric data, sexual orientation, and ethnicity.
Special categories of data ("sensitive data" under GDPR Article 9) — such as health data, genetic data, and information about marital status that we collect for surrogacy coordination — receive enhanced protection. We process such data only with your explicit consent and only for the purposes of delivering your program.
The Data Protection Principles include requirements that personal data:
- Be processed in a fair, legal, and transparent way
- Be used only for legitimate purposes for which it was collected
- Be kept accurate and up-to-date
- Be retained only for as long as necessary
- Be protected against unauthorized access, loss, or destruction
25. Contact Us
If you have any questions about this Privacy Policy or want to exercise your rights, please contact us:
- Email: email loading…
- Phone / WhatsApp: +380 63 758 9561
- Office: Lukyanivska 69/71, Kyiv, Ukraine
- Postal address: Andrii Khodonovych, Lukyanivska 69/71, Kyiv, Ukraine