FetusPlus Consumer Health Data Privacy Notice

Document ID: FP-US-CHD-NOTICE
Version: 1.0 (W1-PUBLIC-2026-10-20.v1.0)
Effective date: October 20, 2026
Supersedes: staging candidate W1-STAGING-2026-08-24.v0.1 (never effective)
Status: EFFECTIVE

This Notice is separate from the general Privacy Notice. It describes how FetusPlus handles consumer health data and the choices available to you. It is intended to be linked prominently from the home page and every material health-data collection surface.

1. Responsible entity

“FETUSPLUS” Limited Liability Partnership, Republic of Kazakhstan, Business Identification Number (BIN) 230740013261 is the current pre-MVP US operator and responsible data entity.

Contact: FetusPlus Care or privacy.fetusplus@gmail.com.

2. What we treat as consumer health data

FetusPlus treats information that identifies or can reasonably be linked to a person and relates to reproductive, sexual, physical or mental health as consumer health data. This includes self-reported information about:

• fertility and reproductive plans;
• IVF, embryos, PGT, clinics and donor involvement;
• pregnancy, birth, C-sections and breastfeeding;
• medications, nicotine/substance use, height, weight or BMI;
• medical or psychological readiness/status;
• insurance or life-insurance readiness;
• twins, selective reduction and termination-related preferences;
• matching or relationship activity that reveals a person's effort to seek reproductive or surrogacy-related services;
• precise location if it could indicate a visit to a health-care facility;
• inferences created from the information above.

FetusPlus may treat additional information as sensitive even if a particular law uses a narrower definition.

FetusPlus does not ordinarily collect clinic/EHR/lab records, physician reports, psychological reports, signed surrogacy agreements, insurance-policy documents, escrow records or background-check reports as normal product content.

3. Sources

Consumer health data may come from:

• you;
• another participant through an accepted, specific workflow;
• an Agency acting within a documented authority and purpose;
• product activity that reveals a matching or reproductive-service context;
• a service provider acting only under FetusPlus instructions.

FetusPlus does not purchase consumer health data from data brokers.

4. Purposes

FetusPlus uses consumer health data only to:

• provide role-specific profile, readiness and matching functions;
• determine whether a requested product action is available;
• display approved information to a permitted participant;
• support consent-based matching and Agency workflows;
• protect safety, integrity, security and user rights;
• investigate incidents and comply with law;
• maintain consent, version and audit evidence.

FetusPlus does not use consumer health data for targeted advertising, sale, unrelated marketing or generalized profiling.

5. Collection consent

Before collecting consumer health data, FetusPlus must display a separate opt-in consent that clearly states:

• the categories collected;
• the purpose;
• how to withdraw;
• the categories of recipients;
• a link to this Notice.

The consent is not valid if it is pre-checked, hidden in the Terms, obtained through deceptive design or inferred from silence.

You may decline. A feature that requires the data may remain unavailable, but FetusPlus will not punish you for declining.

6. Sharing consent and recipients

FetusPlus may share consumer health data with:

• an intended parent or gestational carrier in an exact matching context;
• an Agency acting for a selected intended parent within an accepted relationship and purpose;
• a service provider needed to host, secure, deliver or support the service;
• a regulator, court or other party when valid law requires it or a legal claim/safety emergency permits it.

Before sharing with another platform participant or Agency where a specific consent is required, FetusPlus must present a distinct contextual choice identifying the recipient category, purpose and data scope. A general Terms acceptance or collection consent is not a substitute.

Other users must not use health data outside the authorized purpose, republish it, scrape it or use it for unrelated marketing.

7. Affiliates and service providers

At the proposed publication point, FetusPlus has no accepted current affiliate that may independently use consumer health data. A future Delaware or other affiliated entity may not receive the data until a controlled transition, notice and required choices are completed.

The exact production service-provider names, locations, functions and contracts must appear on the Subprocessor page before this Notice becomes effective. Service providers may process data only under binding instructions, confidentiality, security, incident and deletion-assistance obligations.

8. Sale, advertising and geofencing

FetusPlus does not sell consumer health data and does not exchange it for money or other valuable consideration.

FetusPlus does not share consumer health data for targeted or cross-context behavioral advertising, build advertising audiences from it or allow advertising pixels/SDKs to receive it.

FetusPlus does not use geofencing around health-care facilities to identify, track, collect from or send health-related messages to people.

A current Google Tag Manager reference exists on public pages. It must be removed or verified through exact tag and network evidence before this Notice can become effective. No tag may run on questionnaire, profile, matching, chat, Care, Agency application, identity or other sensitive/authenticated surfaces without a separate accepted decision.

9. Your rights

Subject to applicable law and reasonable identity verification, you may:

• confirm whether FetusPlus collects, shares or sells your consumer health data;
• access the data;
• obtain a copy;
• correct it;
• delete it;
• withdraw collection or sharing consent;
• obtain a list of categories of third parties and, where required, specific third parties or affiliates;
• appeal a refusal.

Submit a request through FetusPlus Care or privacy.fetusplus@gmail.com. Use the subject “Consumer Health Data Request.” Appeal by replying with “Consumer Health Data Appeal.”

FetusPlus targets a response within 30 calendar days and follows any legally required shorter/different deadline. A refusal explains the reason and appeal route.

10. Deletion and backups

After a verified deletion request, FetusPlus will:

1. unpublish affected public fields promptly;
2. delete covered active-system data within 30 days unless a documented legal/safety exception applies;
3. direct processors to delete it;
4. isolate backup copies from ordinary use and remove/overwrite them within no more than 35 additional days;
5. re-delete the data if a backup is restored.

A legal or safety hold must have a named owner, case reference, reason, start date and review/expiry date. FetusPlus does not use a hold to continue ordinary product processing.

11. Retention

Consumer health data is retained only while needed for the active purpose and consent, then deleted under the general Privacy Notice's schedule. Consent and version evidence may be retained for six years. Matching/message evidence may be retained up to three years where necessary for safety, disputes or integrity, with restricted access.

12. Security

FetusPlus uses access restrictions, authentication, encryption, logging, backup controls, incident response and processor obligations appropriate to sensitive information. No system is completely secure.

Unauthorized access or disclosure is treated as a potential health-data breach until assessed.

13. Changes

A material change to the categories, purposes or sharing requires a new version and, where required, new opt-in consent before the changed processing begins.

14. Contact

• FetusPlus Care in the product
• privacy.fetusplus@gmail.com
• fetusplus.com

This Notice does not limit a right or remedy available under applicable law.