FetusPlus USA Privacy Notice

Document ID: FP-US-PRIVACY
Version: 1.0 (W1-PUBLIC-2026-10-20.v1.0)
Effective date: October 20, 2026
Supersedes: staging candidate W1-STAGING-2026-10-20.v0.2 (never effective)
Status: EFFECTIVE

This Notice explains how FetusPlus processes personal information for the pre-MVP US service. The separate Consumer Health Data Privacy Notice provides additional information and rights for reproductive, fertility, pregnancy and related data.

1. Who is responsible

The current operator and responsible data entity is “FETUSPLUS” Limited Liability Partnership, a legal entity registered in the Republic of Kazakhstan, Business Identification Number (BIN) 230740013261 (“FetusPlus,” “we,” “us”).

Privacy contact: privacy.fetusplus@gmail.com. Human support is available through FetusPlus Care in the product.

2. Scope and privacy posture

This Notice applies to signed-out visitors, account holders, intended parents, gestational carriers, Agency organizations and staff, applicants, support users and other people whose information is processed through the USA pre-MVP service.

FetusPlus applies a conservative consumer-health-data baseline nationwide. This does not state that every law applies to every person; it means FetusPlus does not lower core protection merely because a threshold or jurisdiction may be uncertain.

FetusPlus is not relying on HIPAA as the privacy model for this service.

3. Information we may process

Account and security

• email, internal account identifiers and verification status;
• mobile phone number where you provide one, its verification status and your text-message (SMS) choice;
• authentication, session, MFA, recovery and security signals;
• device, IP address, diagnostic, fraud-prevention and access-log data.

Authentication secrets are not ordinary user-visible or Ops-visible profile fields.

Profile and role information

• public display name or alias;
• role, state-level location, languages, family/profile information;
• profile text, approved public fields, moderation and publication status;
• photos where enabled and approved.

Reproductive, health and sensitive information

Depending on role and flow, this may include self-reported:

• fertility, IVF, embryo and donor status;
• pregnancy, birth, C-section and breastfeeding history;
• health, body-measurement, nicotine or substance information;
• readiness, timeline, insurance, clinic and attorney status;
• sensitive compatibility preferences, including twins, selective reduction and termination-related positions;
• family structure, ethnicity/heritage or other sensitive information where the product asks for it.

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

Activity and communications

• Interests, requests, Mutual Interest, Hold, Match Meeting, Match Request and Match state;
• messages, delivery states, reports and safety-review records;
• FetusPlus Care submissions and responses;
• Agency application, profile, relationship and attestation records;
• consent, acknowledgement, version and audit records.

Payment information

Payment integrations may exist in code, but pre-MVP FetusPlus billing is off. FetusPlus does not authorize real pre-MVP platform charges under this Notice. Exact payment architecture must be separately verified before any payment activation.

4. Sources

We may receive information:

• directly from you;
• from another participant acting through a specific accepted workflow;
• from an Agency acting within an accepted authority and purpose;
• from product, authentication, security and fraud-prevention systems;
• from service providers acting under instructions;
• from Yana/Ops recording an accepted action;
• from public sources or legally valid requests where specifically permitted.

We do not treat another participant's access as authority to provide unrelated information about you.

5. Why we use information

We use information to:

• create, authenticate and secure accounts;
• provide profiles, limited previews, discovery and matching workflows;
• operate messages, FetusPlus Care and permitted contact-sharing steps;
• apply role, publication, consent, moderation, safety, capacity and state-availability rules;
• prevent fraud, abuse, security incidents and unauthorized access;
• process rights, withdrawal, deletion and appeal requests;
• maintain version, consent, audit and incident evidence;
• troubleshoot, maintain and improve service reliability;
• comply with applicable legal obligations and enforce the Terms.

We do not reuse consumer health data for unrelated advertising, sale or generalized profiling.

6. Public and gated visibility

Signed-out visitors may see only the accepted public safe-preview fields. Public fields may be indexed by search engines.

Other users see only the fields allowed for their role, relationship and lifecycle state. Safe Preview, full profile, sensitive matching information, messages, photos and contact details are different access layers.

FetusPlus does not automatically show stored phone numbers or email addresses to matching participants. Internal reasons, exact activity dates, hold reasons, queue positions, private lifecycle codes and protected safety information are not public profile content.

7. Consent and choices

Consumer health data collection

Before FetusPlus collects consumer health data, the interface must present a separate, specific opt-in collection consent. It is not bundled into the Terms.

Consumer health data sharing

Where a flow shares consumer health data with another participant or Agency, FetusPlus must present a distinct contextual choice that identifies the purpose and recipient category. General acceptance of the Terms is not sufficient.

Profile publication and photos

Publishing a profile is a separate user action subject to moderation and product gates. Personal photos are not public to signed-out visitors. Photo visibility follows the exact approved role/access rules.

Withdrawal

You may withdraw a consent through the applicable product control or by contacting privacy.fetusplus@gmail.com. Withdrawal does not make prior lawful processing retroactively unlawful, but it stops future processing that depends only on that consent and may make a feature unavailable.

8. SMS / Text Messaging

If you opt in to receive text messages, we use your mobile phone number to send you account alerts and reminders related to your FetusPlus account — for example, an unfinished profile, the result of a profile review, a new Interest or message waiting for your reply, Hold and Match requests that need your response, Match confirmation, and reminders for scheduled meetings. Message frequency varies. Message and data rates may apply. You can opt out at any time by replying STOP to any message, by turning off text messages in your Profile Settings, or by contacting help@fetusplus.com. Reply HELP for assistance.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors that support our services, such as customer service or message delivery, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Text messages are a separate, optional choice. Consent is not a condition of using FetusPlus, is never pre-checked and is not inferred from acceptance of the Terms. FetusPlus does not send marketing or promotional text messages under this consent. We keep a record of your opt-in and opt-out (date, time, phone number, the exact text you agreed to and the method used) as consent evidence under the retention schedule in this Notice. Text messaging is governed by the Mobile Messaging Terms at fetusplus.com/sms-terms.

9. Recipients and disclosures

We may disclose information only as reasonably necessary to:

• another participant or Agency under the exact role, relationship, purpose and consent rules;
• service providers that host, secure, deliver or support the service under written instructions;
• professional advisers chosen by FetusPlus for a bounded matter;
• authorities or other parties when required by valid law, necessary to protect rights or safety, or permitted for a legal claim;
• a successor entity in an accepted future corporate transition, with notice and protection of applicable rights.

We do not disclose consumer health data to data brokers or advertising platforms.

The exact production provider list, processing locations and contracts must be verified and published at the Subprocessor page before this Notice becomes effective. If that list is incomplete, collection of new consumer health data must remain off.

10. No sale, targeted advertising or health geofencing

FetusPlus does not:

• sell personal information or consumer health data;
• share consumer health data for cross-context behavioral or targeted advertising;
• use consumer health data to build advertising audiences;
• use a geofence around a health-care facility to identify, track, collect from or send health-related messages to people.

Any tag-management, analytics or advertising code must be inventoried. It must be removed from sensitive/authenticated flows or proven, by exact configuration and network evidence, not to receive consumer health or sensitive data. Publication is blocked until the current Google Tag Manager reference is resolved.

11. Cross-border processing

FetusPlus is operated from Kazakhstan. Information may therefore be accessed or processed in Kazakhstan and in the verified locations of approved service providers.

Privacy and consumer-protection laws may differ across countries. FetusPlus uses the notices, consent, access controls, contracts, deletion assistance, incident duties and security measures described here to protect information during cross-border processing.

A later transition to a Delaware or other US entity requires a separate accepted controller/contract/data-transfer change and updated notice. No silent operator change is allowed.

12. Retention

FetusPlus follows the candidate retention schedule accepted for the pre-MVP service:

A documented legal or safety hold may extend a period only for a defined case, reason, owner and review/expiry date. Indefinite silent holds are prohibited.

The live system must be evidenced against this schedule before publication. If a real system cannot meet a stated period, the text and system must be reconciled before GO.

13. Your rights

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

• confirmation whether FetusPlus processes your information;
• access to and a copy of your information;
• correction of inaccurate information;
• deletion;
• withdrawal of consent;
• a list of categories of recipients and, where required, specific third parties or affiliates;
• an appeal of a refusal;
• information about an automated protection decision and human review where applicable.

Submit a request through FetusPlus Care or privacy.fetusplus@gmail.com. State the right you want to exercise and the account email. Do not send identity documents by ordinary email unless FetusPlus gives a secure, specific method.

FetusPlus targets a response within 30 calendar days and will meet a shorter or different legally required deadline. If additional time is legally permitted and necessary, FetusPlus will explain the reason and new date.

If a request is refused, the response will explain the basis and how to appeal. Appeal by replying with “Privacy Appeal” or using FetusPlus Care. Appeals are reviewed by a person who did not make the original decision where practicable.

FetusPlus does not discriminate against a person for exercising a privacy right, but deleting data or withdrawing a necessary consent may make a feature unavailable.

14. Security

FetusPlus uses role-based access, authentication, least-privilege controls, encryption appropriate to the data, logging, secret management, backup controls, vulnerability remediation and incident procedures.

No system is completely secure. You are responsible for protecting your credentials and promptly reporting suspected compromise.

Exact hosting, database, storage, email, monitoring and identity-provider facts remain publication evidence items and must not be inferred from this Notice.

15. Fetus AI and Safety Guardian

Fetus AI is not authorized to process production user data until its provider, model, processing location, retention, training use, subprocessors, deletion and contract settings are accepted and disclosed.

When enabled, Fetus AI receives only the context allowed for the request/session. It does not automatically read all human chats. Selected-message sharing remains disabled unless a user selects one exact excerpt, sees it, confirms one-request private use and the accepted technical/privacy controls are live.

Safety Guardian may process message attempts to apply disclosed platform protections. A timeout is not a risk finding. High-impact decisions remain human-controlled. Safety records are retained only under the applicable schedule and access controls.

16. Children

The pre-MVP service is for adults. FetusPlus does not knowingly permit accounts for people under 18. If you believe a minor provided information, contact privacy.fetusplus@gmail.com.

17. Incidents and health-data breaches

FetusPlus maintains an incident route for containment, evidence preservation, access revocation, secret rotation, rollback, investigation and legally required notice.

Unauthorized access or disclosure of health-related information is treated as a potential health-data breach until assessed. Required notices to affected people, regulators or media are made within the applicable deadlines. FetusPlus does not delay mandatory containment while waiting for a discretionary policy decision.

18. State-specific protections

FetusPlus applies the core protections in this Notice nationwide. Depending on residence or collection location, additional rights may apply, including rights under Washington, Nevada, Connecticut, California or other state law.

A state-specific right does not reduce the rights expressly promised here. FetusPlus may ask for location only to identify applicable rights, not to infer sensitive health activity.

19. Changes

Material changes are versioned and communicated. Where a change requires consent, FetusPlus requests a new specific opt-in before the changed processing. Historical versions and acceptance/consent records are preserved.

20. Contact and appeal

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

Use the subject “Privacy Request,” “Consumer Health Data Request,” “Privacy Appeal” or “Security Incident,” as applicable.