Privacy Policy
Version dated 03.04.2026
1. General Provisions
1.1. This Privacy Policy (hereinafter — "Policy") defines the procedure for collecting, processing, storing, and protecting personal data of individuals (hereinafter — "Data Subjects") who interact with the website friendlyfamily.com.ua (hereinafter — "Website") or contact the Friendly Family agency in any other way.
1.2. The legal basis of this Policy includes:
–Constitution of Ukraine (Article 32 — inviolability of personal and family life, non-interference in private life);
–Law of Ukraine "On Personal Data Protection" dated 01.06.2010 No. 2297-VI (as amended);
–Law of Ukraine "On Information" dated 02.10.1992 No. 2657-XII (as amended);
–Civil Code of Ukraine (Chapter 22 — personal non-property rights);
–EU General Data Protection Regulation (GDPR, Regulation EU 2016/679) — applies to the processing of data of residents of the European Economic Area when contacting the Agency.
1.3. Terms and definitions:
–Agency — the business entity Friendly Family, which carries out administrative and organizational activities for the selection of candidates for participation in surrogacy and egg donation programs, and is the Owner of personal data within the meaning of the Law "On Personal Data Protection".
–Partner Clinic — a licensed healthcare facility (medical center) with which the Agency cooperates on the basis of an agreement. The Partner Clinic is an independent entity for processing medical personal data based on its own MOH license.
–Data Subject — any individual whose personal data is processed by the Agency.
–Personal data processing — any action or set of actions performed in whole or in part in information (automated) systems and/or personal data filing systems: collection, registration, accumulation, storage, adaptation, modification, renewal, use and distribution, anonymization, destruction of personal data.
Friendly Family Agency performs exclusively administrative and coordination functions. Medical procedures, including examinations, hormonal stimulation, follicle puncture, embryo transfer and pregnancy management, are carried out by the Partner Clinic under its medical license. Medical personal data is processed by the Partner Clinic as an independent Owner in accordance with its own policies and healthcare legislation requirements.
2. Categories of Personal Data
2.1. Data collected through website forms: full name, mobile phone number, email address, message content, preferred contact method (call/message).
2.2. Automatically collected data: IP address, browser type and OS, date/time of visit, page URLs, cookies as per Section 9.
2.3. Data provided during consultations: age, place of residence, general eligibility information.
2.4. Data NOT collected: data on race/ethnicity, religious beliefs, criminal records, genetic/biometric data, financial details.
3. Purpose and Legal Basis of Processing
3.1. Legal basis: data subject consent via active confirmation on the website; contract performance; legitimate interest of the Agency.
3.2. Purpose: processing applications; consultations; eligibility assessment; data transfer to Partner Clinic (with explicit consent); contract fulfillment; informing about program changes; compliance with legislation.
The Agency does not use personal data for profiling, automated decision-making, targeted advertising of third parties, or transfer of data to advertising networks.
4. Data Retention Periods
4.1.1. Contact form data (before contract): 12 months from submission or until consent is withdrawn — whichever comes first.
4.1.2. Program participant data (after contract): during the contract and 3 years after termination — per Art. 257 of the Civil Code of Ukraine.
4.1.3. Technical data (logs, cookies): as per Section 9 of this Policy.
4.2. After the retention period, data is destroyed or anonymized in a way that prevents recovery and identification.
5. Disclosure to Third Parties
5.1. The Agency does not sell, lease, or disclose personal data to third parties for commercial purposes.
5.2.1. Partner Clinic. Candidate contact data is transferred to the licensed medical facility only after obtaining explicit consent.
5.2.2. Technology service providers (data processors). The Agency may engage third parties for website support (hosting, email, analytics). They act exclusively as data processors under contract.
5.2.3. Legal requirements. Personal data may be disclosed to authorized government bodies (courts, law enforcement, the Ukrainian Parliament Commissioner for Human Rights) exclusively on the basis and in the manner prescribed by current Ukrainian legislation.
5.3. If in the future there is a need to transfer data to other categories of recipients, the Agency will notify the data subjects and obtain the appropriate consent.
6. Data Subject Rights
6.1. Under Art. 8 of the Law "On Personal Data Protection", data subjects have the right to:
–Right of access. Obtain confirmation of the fact of processing of your data, information about the purpose, composition, sources and terms of their storage.
–Right to rectification. Request correction of inaccurate or outdated data.
–Right to erasure ("right to be forgotten"). Request deletion of your data — provided there are no legal grounds for their further processing (e.g., a valid contract or legal requirement).
–Right to restriction of processing. Request suspension of data processing for the period of review of objection regarding their correctness or legality.
–Right to object. Object to processing carried out on the basis of legitimate interest, if the rights and interests of the subject prevail over such interest.
–Right to withdraw consent. Withdraw given consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent does not affect processing on other grounds (contract performance, legal requirements).
–Right to complaint. File a complaint with the Ukrainian Parliament Commissioner for Human Rights (21/8 Instytutska St., Kyiv, 01008; www.ombudsman.gov.ua).
6.2. To exercise any of the listed rights, the data subject sends a written request by email or in writing to the contact details specified in Section 10. The Agency reviews the request and provides a response within 30 calendar days from the date of its receipt.
6.3. To verify identity when making a request, the Agency may ask the subject to present an identity document or undergo another reasonable method of verification.
7. Data Protection
7.1. The Agency implements technical and organizational measures: minimum privilege access control; encrypted secure server storage; HTTPS/TLS; regular security reviews; personnel confidentiality obligations.
7.2. In case of a data breach posing risk to data subjects' rights, the Agency takes immediate containment measures and notifies affected subjects within the legally prescribed timeframe.
8. Minors
8.1. The website and Agency services are intended exclusively for adults (18+). The Agency does not knowingly collect data of persons under 18.
8.2. If the Agency discovers that data was provided by a person under 18, such data will be deleted immediately.
9. Cookies
9.1. The website may use cookies: necessary (technical) — no consent required; analytical (e.g. Google Analytics) — consent required; marketing — consent required.
9.2. On first visit, a cookie notice is displayed with category selection. Visitors can withdraw consent via browser settings.
9.3. Technical cookies are stored for the session or up to 12 months. Analytical and marketing cookies — per the service provider's terms.
10. Contact Information
10.1. For data subject rights, consent withdrawal, and any other inquiries: phone +380 (95) 089-52-55; website friendlyfamily.com.ua; Instagram @yuzkodonation__surrogate.
10.2. The Agency processes requests within 30 calendar days. In exceptional cases, the period may be extended by 60 days with notification.
11. Changes to the Privacy Policy
11.1. The Agency reserves the right to amend this Policy. The updated version is published on the website with the effective date.
11.2. Continued use of the website after changes constitutes acceptance of the updated Policy.
11.3. Previous versions are archived and available upon request.
12. Applicable Law and Dispute Resolution
12.1. This Privacy Policy is governed by the laws of Ukraine.
12.2. Disputes are resolved through negotiation; if impossible — in court under Ukrainian law.
12.3. The data subject may file a complaint with the Ukrainian Parliament Commissioner for Human Rights (21/8 Instytutska St., Kyiv, 01008; www.ombudsman.gov.ua) regardless of court proceedings.
Effective date: 03.04.2026
Friendly Family | Chernivtsi, Ukraine