Privacy Statement

Last Updated: December 1, 2023

Fertility Travel Inc values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, your rights in determining what we do with the information that we collect or hold about you and

tells you how to contact us.

Privacy Statement Summary

This is a summary of our Privacy Statement.

What does this Privacy Statement cover?

This Privacy Statement is designed to describe:

• How and what type of personal information we collect and use
• When and with whom we share your personal information
• What choices you can make about how we collect, use, and share your personal information
• How you can access and update your information.

What personal information do we collect and use, and how do we collect it?

We collect personal information when:

• You give us the information
• We collect it automatically
• We receive it from others

When you sign up to receive information, or schedule a call with us, you give us your personal information.

We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites or download and use our Apps, if applicable.

How is your personal information shared?

Your personal information may be shared for several purposes, including: to help you book your fertility travel clinic appointment, assist in securing your donor selection, assist with your airline or ground travel booking, assist with booking your hotel accommodations, communicate with you (including when we send information on products and services or enable you to communicate with travel providers and/or property owners), and comply with the law. The full Privacy Statement below details how personal information is shared below.

What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our Privacy Statement has more information about the options and data protection rights and choices available to you.

How to contact us

More information about our privacy practices, you can contact us as described below in the "Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.

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Categories of Personal Information We Collect

When you use our platform, Apps, or associated tools or services, we may collect the following kinds of personal information from you as needed:

• Name, username, email address, telephone number, and home, business, and billing addressees (including street and postal code)
• Government issued Identification required for booking or identity verification, such as passport, driver’s license, government redress numbers, and country of residence (for travel insurance purposes).
• Payment information such as payment card number, expiration date, billing address, and financial account number
• Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs, as available
• Loyalty program and membership information
• Birth date and gender
• Geolocation
• Images (including facial photographs), videos, and other recordings
• Social media account ID and other publicly available information
• Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes)
• Searches you conduct, transactions, and other interactions with you on our online services, website or available Apps
• Other communications that occur through the platform among partners and travelers, and in-group chat and traveler-collaboration tools
• The searches and transactions conducted through the platform
• Data you give us about other people, such as your travel companions or others for whom you are making a booking
• Information we receive about you from Fertility Travel’s KIWI app, Fertility Travel Trip Creator App, Salesforce or other third parties such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis

We collect sensitive personal information either with consent or in accordance with local law. This may include information which could reveal your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, and health or disability information.

When you install any of our apps or use our platform, we automatically collect the following types of information from your device (“Automatically Collected Information”):

• IP address
• Device type
• Unique device identification numbers
• Internet browser-type (such as Firefox, Safari, Chrome, and Internet Explorer)
• Internet Service Provider
• Operating System
• Mobile carrier
• How your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times
• Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

Use of Personal Information

We use your personal information for various purposes described below, which depend on the site you visit or the app you use.

Your Use of Online Sites, Apps and Services:

• Book the requested travel or enable hotel property booking
• Provide services related to the booking and/or account
• Create, maintain, and update user accounts on our platform and authenticate you as a user
• Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Fertility Travel platform and services, and as otherwise described in this Privacy Statement
• Enable and facilitate acceptance and processing of payments, coupons, and other transactions
• Collect and enable booking-related reviews

Communications and Marketing:

• Respond to your questions, requests for information, and process information choices
• Enable communication between you and the fertility clinic, the egg and sperm donor clinic, the travel supplier for both air and ground transportation and accommodations.
• Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement
• Market our products and services
• Analyze information such as browsing and/or purchase history and use the result to optimize advertising in accordance with your interests and preferences
• Measure and analyze the effectiveness of our marketing and promotions

Other Business Purposes and Compliance

• Conduct surveys, market research, and data analytics
• Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services
• Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement•Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible
• Promote security, verify identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks
• Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process
• Operate our business using lawful business purposes and as permitted by law

Sensitive Personal Information

We will only use your sensitive personal information for the purposes for which it was collected.

Lawful bases for processing:

We will collect personal information from you only (i) where the personal information is necessary to perform a contract with you (e.g., manage your booking, process payments, secure clinic appointments, or create an account at your request), (ii) where the processing is in our legitimate interests and not overridden by your rights (as explained below), or (iii) where we have your consent to do so (e.g., sending you marketing communications where consent is required). In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Certain countries and regions allow us to process personal information on the basis of legitimate interests. If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities.

We may use artificial intelligence, machine learning, and other automated decision-making to enhance your

user experience and keep our site safe. For example, we may use it in relation to:

• Clinic destinations, hotel property or area activity recommendations,
• flight price insights and alerts,
• the reviews you share with us to ensure they do not contain identifiable personal information or to assess customer satisfaction,
• the prevention and detection of breach of our terms and conditions or other fraudulent activities to keep our site safe,
• our language and dialects within our client representative's experience.

Automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes.

We will not engage in automated decision-making that involves a decision with legal or similarly significant effects solely based on automated processing of personal information, unless you: (1) explicitly consented tothe processing, (2) the processing is necessary for entering into a contract, or (3) when otherwise authorized by applicable law.

You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing.

Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

• Fertility Travel Inc. We share your personal information within Fertility Travel Inc, (either autonomously or as joint data managers, where applicable) and use your personal information as described in this Privacy Statement.
• Third-party service providers. We share personal information with our approved third parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for.

They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).

• Travel suppliers. We share personal information with our approved travel-related suppliers such as hotels, airlines, car-rental companies, and managers, and where available, activity providers, rail, or ground transportation providers who fulfill your booking. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.
• Business partners and offers. If we promote an offer, a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.
• Targeted Advertising. We may disclose your Automatically Collected Information to our third-party marketing partners for targeted advertising. This may be considered “sharing” data under California law. Subject to certain limitations, some US residents have the right to opt out of having their personal information shared for this purpose. For more information, see the “Your Rights and Choices” section below. You should note that by opting out of these types of disclosures, you may limit our ability to customize your experience with content that may be of interest to you or to provide you with a better travel experience. View our Cookie Policy for more information on our use of tracking technology for the purposes of targeted advertising.
• Other Third-Parties. When you access certain features like Facebook’s “Like” button or a single sign-on that allows you to login with your social media credentials to our online services, you will share information with the third-party, like a social media company, such as the fact that you have visited or interacted with us. In the European Economic Area (EEA), Switzerland, and United Kingdom (UK) we will not load social media sharing or sign-on buttons on our website unless and until you accept our use of cookies and similar technologies. For more information, see our Cookie Policy. The third-party provider may combine this information with other information they have about you. The personal information shared will be governed by the third-party provider’s privacy policy (including any personal information we may access via the third-party provider). The third-party providers should inform you about how you can modify your privacy settings on their site.
• Legal rights and obligations. We may disclose your personal information and associated records to enforce our policies; as necessary to satisfy our tax or other regulatory reporting requirements, including the remission of certain taxes in the course of processing payments; or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a subpoena or other legal request, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests.
• Corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Statement.

Your Rights and Choices

You have certain rights and choices with respect to your personal information, as described below:

• If you have an account with us, you may change your communication preferences by either (1) logging in and updating the information in your account, or (2) contacting us.
• You can control our use of certain cookies by following the guidance in our Cookie Policy.
• You can access, amend, inquire about deletion of, or update the accuracy of your information at any time by either logging into your account or contacting us directly.
• If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe.
• If we are processing your personal information on the basis of your consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew your consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent.

Certain countries and regions provide their residents with additional rights relating to personal information.

These additional rights vary by country and region and may include the ability to:

• Request a copy of your personal information
• Request information about the purpose of the processing activities
• Delete your personal information
• Object to our use or disclosure of your personal information
• Restrict the processing of your personal information
• Opt-out of the sale of your personal information
• Port your personal information
• Request information about the logic involved in our automated decision-making used in our fraud prevention practices and the result of such decisions

For questions about privacy, your rights and choices, and in order for you, or (where applicable) your authorized agent to make a request to amend or update your information, or to inquire about deletion of your information, please contact us. In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request directly to us using the contact information on our website.

We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws. Should you have the right to appeal a decision to not take action on a request under applicable law, instructions on how to make that appeal will be included in our response to you.

International Data Transfer

The personal information we process may be accessed from, processed or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.

The servers for our platform are in Denmark and the United States. When we collect your personal information, we may process it in either of these countries. Our employees may access your personal information from various countries around the world. The transferees of your personal data may also be in countries other than the country in which you reside.

We have taken appropriate steps and put safeguards in place to help ensure that any access, processing and/or transfer of your personal information remains protected in accordance with this Privacy Statement and in compliance with applicable data protection law. Such measures provide your personal information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed and/or transferred to.

Privacy Shield

Fertility Travels Privacy Shield frameworks adhere to the Privacy Shield Principles of Notice, Choice, accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability for personal information from the EU, Switzerland, and the United Kingdom. We will strive to adhere to the Privacy Shield frameworks and Principles even though the CJEU determined in July 2020 that the EU-U.S. Privacy Shield framework is no longer an adequate transfer mechanism for the transfer of EU personal information to the U.S. In addition, Fertility Travel will obtain and maintain intra-group Standard Contractual Clauses and certifications, where applicable, to cover the transfer of EU personal information to the U.S.

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

Record Retention

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is requiredor permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

When we delete your personal information, we use industry standard methods to ensure that any recovery or retrieval of your information is impossible. We may keep residual copies of your personal information in backup systems to protect our systems from malicious loss. This data is inaccessible unless restored, and all unnecessary information will be deleted upon restoration.

The criteria we use to determine our retention periods include:

• The duration of our relationship with you, including any open accounts you may have with Fertility Travel companies, or recent bookings or other transactions you have made on our platform
• Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us
• Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations
• Whether your information is needed for secure backups of our systems

Contact Us

If you have any questions or concerns about our use of your personal information or wish to inquire about our personal information handling practices, and exercise your rights to access, correct or inquire about deletion of personal information, please contact us.

Updates to Statement

We may update this Statement in response to changing laws or technical or business developments. If we propose to make any material changes, we will notify you by means of a notice on this page. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Statement.