Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit our website, complete our intake quiz or other forms, or otherwise interact with us (collectively, the "Services").

This Privacy Policy is intended to comply with the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") and other applicable Canadian privacy laws. To the extent that any personal information we handle constitutes "personal health information" under Ontario's Personal Health Information Protection Act, 2004 ("PHIPA"), we will handle that information consistently with PHIPA requirements that apply to us.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

About Us and Our Role

We operate an online directory and referral service that helps individuals locate and connect with fertility clinics and related healthcare providers (each, a "Clinic"). We are not a healthcare provider, medical practice, insurer, or licensed health professional. We do not provide medical advice, diagnosis, treatment, or recommendations regarding fertility care or any other healthcare matter.

Our role is limited to:

• Providing general information about fertility care options and Clinics;
• Collecting information you voluntarily submit through quizzes, forms, or other tools; and
• Transmitting that information to Clinics you choose, or that match the criteria you provide, so those Clinics may contact you directly.

Any healthcare service, consultation, treatment, or advice is provided exclusively by the Clinic — not by us. Your relationship with any Clinic is independent of your relationship with us.

Personal Information We Collect

We collect the following categories of personal information:

a) Information you provide directly:

• Identifiers such as your name, date of birth, age range, and gender identity;
• Contact information such as email address, phone number, postal code, city, and province;
• Quiz, intake form, and survey responses, which may include information about your fertility journey, family-building goals, medical history, reproductive health, lifestyle, preferences, timeline, insurance or funding situation, and other information you voluntarily disclose;
• Preferences regarding the type of Clinic or care you are seeking;
• Communications you send to us (e.g., emails, support requests, feedback);
• Any other information you choose to provide.

b) Information collected automatically:

• Technical information such as IP address, browser type and version, device type, operating system, language preferences, and referring URLs;
• Usage information such as pages visited, time spent on pages, links clicked, and interactions with the Services;
• Cookie and similar tracking data (see Section 8).

c) Information from third parties:

• Information from analytics providers, advertising partners, and service providers;
• Information from Clinics that have interacted with you (e.g., to confirm a referral was received or that an appointment was booked);
• Publicly available information.

Sensitive Information

You may choose to provide sensitive information — such as health information, reproductive history, or information about your medical conditions — through our quizzes or forms. You provide this information voluntarily and at your own discretion. We do not require you to disclose any specific sensitive information to use the Services. Where you do provide sensitive information, you expressly consent to our collection, use, and disclosure of that information for the purposes described in this Privacy Policy.

How We Use Personal Information

We use your personal information for the following purposes:

• Matching and referrals: To identify Clinics that may meet your stated needs and to transmit your information to those Clinics so they may contact you;
• Service delivery: To provide, operate, maintain, and improve the Services;
• Communications: To respond to your inquiries, send transactional emails, and provide customer support;
• Marketing: With your consent (where required), to send newsletters, promotional content, educational materials, and information about Clinics or services that may interest you. You may unsubscribe at any time;
• Analytics and improvement: To understand how users interact with the Services, measure performance, and develop new features;
• Personalization: To tailor content, recommendations, and quiz results to you;
• Legal and compliance: To comply with applicable laws, regulations, court orders, and lawful requests; to enforce our Terms of Use; to detect, prevent, or address fraud, security, or technical issues; and to protect our rights, property, and safety, or those of our users or others;
• Business operations: For accounting, audit, record-keeping, business planning, and corporate transactions (including mergers, acquisitions, financings, or asset sales).

Legal Basis for Processing (Consent)

We rely on your consent as the primary legal basis for collecting, using, and disclosing your personal information. Depending on the sensitivity of the information and the context, your consent may be express (e.g., checking a box, submitting a quiz, clicking a button labelled to indicate consent) or implied (e.g., by your voluntary use of the Services after being notified of this Privacy Policy).

By submitting a quiz, form, or other request through the Services, you expressly consent to our collection, use, and disclosure of the personal information you provide for the purposes described in this Privacy Policy — including, without limitation, our transmission of your information to one or more Clinics so that those Clinics may contact you directly.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting us. Withdrawing consent may affect our ability to provide you with the Services or to fulfill referrals already in progress. Withdrawing consent does not require any Clinic that has already received your information to delete it; you must contact that Clinic directly to address their handling of your information.

How We Disclose Personal Information

We disclose your personal information in the following circumstances:

a) To Clinics: When you complete a quiz, form, or other request indicating you wish to be connected with a Clinic, we share your information with one or more Clinics so they may contact you. Once your information has been transmitted to a Clinic, that Clinic is independently responsible for its own collection, use, disclosure, retention, and security of your information, in accordance with its own privacy practices and applicable laws. We are not responsible for the privacy practices of any Clinic.

b) To service providers: We share information with third-party service providers who perform services on our behalf — such as hosting, data storage, email delivery, analytics, customer support, payment processing (if applicable), marketing, and security. These service providers are contractually required to safeguard your personal information and use it only for the purposes for which we engaged them.

c) To advisors and successors: We may disclose information to our professional advisors (lawyers, accountants, auditors, insurers), and to actual or prospective purchasers, investors, or successors in connection with a corporate transaction such as a merger, acquisition, financing, restructuring, or sale of assets.

d) For legal and safety reasons: We may disclose information where we believe in good faith that disclosure is required or permitted by law, court order, subpoena, regulatory request, or other legal process; to investigate, prevent, or take action regarding suspected illegal activities, fraud, security issues, or violations of our Terms of Use; or to protect the rights, property, or safety of us, our users, or others.

e) With your direction or consent: We may disclose information for any other purpose with your consent or at your direction.

We do not sell your personal information.

International Data Transfers

We are based in Ontario, Canada, but some of our service providers, including hosting, analytics, email, and other technology providers, may operate or store data outside of Ontario, including in other Canadian provinces, the United States, or other jurisdictions. While your personal information is stored or processed outside of Canada, it may be subject to the laws of that jurisdiction, including lawful access by courts, law enforcement, and government authorities in that jurisdiction.

We take reasonable steps to ensure that your information receives a comparable level of protection wherever it is processed, including through written agreements with service providers. By using the Services, you acknowledge and consent to this cross-border transfer and processing.

Cookies, Analytics, and Tracking Technologies

We use cookies, pixels, tags, and similar tracking technologies to operate the Services, remember your preferences, analyze how users interact with the Services, measure marketing effectiveness, and personalize content.

Types of cookies we may use:

• Strictly necessary cookies — required for the Services to function;
• Performance and analytics cookies — help us understand how users interact with the Services (e.g., Google Analytics);
• Functional cookies — remember your preferences and settings;
• Marketing and advertising cookies — used by us or third parties to deliver and measure ads.

You can control or disable most cookies through your browser settings. Disabling cookies may affect the functionality of the Services. Where required by law, we will request your consent before placing non-essential cookies, and you may withdraw your consent at any time.

We may use third-party analytics and advertising tools, including but not limited to Google Analytics, Meta (Facebook) pixel, and similar services. These third parties have their own privacy policies that govern their handling of your information.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and maintain business records. Retention periods vary depending on the type of information, the purpose for which it was collected, and applicable legal requirements.

When personal information is no longer required, we will securely destroy, erase, or anonymize it in accordance with our retention policies.

How We Protect Your Information

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss, or destruction. These safeguards include access controls, encryption in transit, secure storage, employee training, and contractual obligations on service providers.

No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials (if any) confidential and for notifying us promptly of any suspected unauthorized access. To the maximum extent permitted by law, we are not liable for unauthorized access, use, or disclosure of your personal information that occurs through no fault of our own.

In the event of a privacy breach involving a real risk of significant harm to you, we will notify you and, where required, the Office of the Privacy Commissioner of Canada or other applicable regulator, in accordance with our legal obligations.

Your Privacy Rights

Subject to applicable law and certain legal exceptions, you have the following rights with respect to your personal information:

• Access: You may request access to the personal information we hold about you;
• Correction: You may request correction of inaccurate or incomplete personal information;
• Withdrawal of consent: You may withdraw your consent to our collection, use, or disclosure of your personal information, subject to legal and contractual restrictions and reasonable notice;
• Complaint: You may file a complaint about how we handle your personal information.

We will respond to your request within the time period required by applicable law. We may need to verify your identity before fulfilling your request. We may charge a reasonable fee where permitted by law for access requests.

We may decline a request where required or permitted by law (for example, where complying would reveal personal information about another person, would compromise an investigation, or where the request is frivolous or vexatious).

Children's Privacy

The Services are intended for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If you are under 18, please do not use the Services or submit any personal information. If we learn that we have collected personal information from a person under 18, we will delete that information promptly.

Third-Party Websites and Services

The Services may contain links to third-party websites, applications, or services, including Clinics' own websites. We are not responsible for the content, privacy practices, or operation of any third-party site or service. This Privacy Policy applies only to the Services. We encourage you to read the privacy policies of any third party before providing them with personal information.

Quiz Match Results and Permalinks

When you complete an intake quiz and submit your contact information, we store your submission together with the personalized list of Clinic matches we generated for you. So you can return to your matches later, we make your results available at a unique URL that includes a randomly generated identifier (a "Results Permalink"). The Results Permalink is not indexed by search engines and is not discoverable through our website navigation, but it is not password-protected: anyone who obtains the URL — for example, if you share it, save it on a shared or public device, or forward an email that contains it — could view your match results.

You are responsible for safeguarding any Results Permalink we provide to you. If you want us to delete your match results or revoke access to a Results Permalink, please contact us and we will action your request in accordance with applicable law.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technologies, legal requirements, or for other reasons. When we make changes, we will revise the policy and, where appropriate, notify you by email or through a notice on the Services. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

Complaints

If you have a concern or complaint about how we handle your personal information, please first contact us and we will work with you in good faith to resolve your concern.

If you are not satisfied with our response, you may file a complaint with:

Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Toll-free: 1-800-282-1376 Website: https://www.priv.gc.ca

To the extent PHIPA applies, complaints may also be directed to:

Information and Privacy Commissioner of Ontario 2 Bloor Street East, Suite 1400 Toronto, Ontario M4W 1A8 Toll-free: 1-800-387-0073 Website: https://www.ipc.on.ca