At SeedTrust, your privacy is important to us. This Privacy Policy describes the personal data that SeedTrust, Inc. and group companies (collectively referred to as “the Company,” “we,” “our,” and “us”) processes. This Privacy Policy also explains how we process personal data and for what purposes.

Summary of Key Points

• This Privacy Policy explains when we process personal data for our legitimate business interests. For more information on how to access and control your data, please see the “How you can control your data” section.
• We do not sell your data.
• We comply with relevant privacy regulations.

Who we are

We provide websites (“Sites”) where visitors and other members of our community (“Visitors”) may learn about our offerings, view Site materials, and/or access our platform (“Platform”) and related services (“Services”) that enable (i) agencies, agency representatives, intended parents, intended parent representatives, gestational surrogates and gestational surrogate representatives(collectively “Clients”) to manage their escrow account with various activities and (ii) individuals (“Visitors”) to consume various forms of content.

How we collect personal data depends on how and why you use our Sites, our Platform, and/or our Services.

We collect personal data directly when you submit it to us as a Client, as well as indirectly, such as through the use of automated technologies or from third parties. To help keep our databases current and to provide you with the most relevant content and experiences, we may combine information provided by you with information from third-party sources in accordance with applicable laws. We provide more information about how we collect personal data below.

SeedTrust uses your personal data for certain legitimate business purposes, including the following:

• to provide you access to and use of the Platform and Services, including registering as a Client,
• to deliver the Platform and Services to our Clients
• to improve and enhance your experience with the Platform and Services, including the content and general administration of the Platform and Services,
• to retain records as may be required for tax, legal, and financial purposes,
• to understand how you access, use, and interact with the Services in order to provide technical functionality, develop new products and services, and analyze your use of the Services,
• to communicate with you,
• to provide you with support in connection with your use of the Services,
• to detect fraud, illegal activities, or security breaches,
• to receive and make payments, and
• to provide information to regulatory bodies when legally required.

In the sections below, we are more specific about the purposes for which we use each category of data.

Data provided by or collected from our Visitors (“Visitor Data”)

When Visitors use or browse one of our Sites, we collect their IP addresses and usage information such as page views, clicks, and browser type.

If a Visitor requests to watch a webinar, subscribes to our blog or other news, submits a request through our Contact Us form, or requests to download a whitepaper or other content, we may also collect the Visitor’s: name, title, email, phone number, company name, country, and IP address.

We use this Visitor Data to provide the Visitor with the information or materials requested, including marketing materials, newsletters, and other related content, perform analytics on how the Site, Platform, and Services are used, improve the use of the Site, Platform, or Services, and for other legitimate business purposes.

SeedTrust uses Recordings to provide Services to Clients, to market its products and services, to protect against fraudulent or illegal activity, to improve the SeedTrust Platform and Services, and for other legitimate business purposes.

Data provided by our Clients (“Client Data”)

During a Client’s use of the Platform and Services, Client’s employees are asked to provide information such as name and contact information, including email address, address, telephone, or other relevant personal data.

Client Data is used by SeedTrust to identify each Client and provide them with access to the Platform and Services, to manage requests from Clients, and to meet SeedTrust’s contractual obligations. We also use Client Data to improve our Platform and Services and to provide Clients with notices about improvements and best practices in using the Platform and Services, as well as other legitimate business purposes.

Tracking Data, IP Addresses and Device Fingerprints

SeedTrust tracks whether a Visitor lands on the SeedTrust Sites from an external source (such as a link on another website or in an email), as well as IP addresses from which the site is accessed and information about the computing device (fingerprint) used to access the Sites. SeedTrust uses this information to improve the Site, Platform, and Services, as well as to prevent fraud and secure information.

Information from Third Parties

SeedTrust collects personal data and other data from third parties that provide us with lists of potential Clients and their contact information if such potential Clients give permission to those third parties to share their information with us. SeedTrust uses this information for its own marketing purposes.

Cookies

We use cookies and other technologies to track the use of our websites and apps.

Visitors have the ability to accept or decline cookies that are not strictly necessary. Most web browsers automatically accept cookies, but individuals can usually modify browser settings to decline cookies. More information about disabling cookies is available at www.allaboutcookies.org. Choosing to decline certain cookies may result in decreased functionality on SeedTrust Site, Platform, and Services.

“Do Not Track”

SeedTrust’s Site, Platform, and Services may not respond to Do Not Track (“DNT”) signals. For more information on DNT settings generally, please visit https://allaboutdnt.com/.

We collect data when you communicate with us

If you communicate with us directly, we will collect any personal data contained in such communications.

Automated decision making

SeedTrust may use automated decision-making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity or who have not engaged with us for an extended period of time. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request a human review of the suspension decision.

How we share your personal data

Data Processors and Subprocessors

SeedTrust discloses personal data to our third-party agents, contractors, or service providers who are hired to perform services on our behalf. These providers may operate or support certain functions of the Services, and in some cases collect information directly. Below is an illustrative list of functions for which we may use third-party service providers:

• Hosting and content delivery network services, such as AWS
• Banking and payment providers, such as Divvy

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, and other businesses or business units. We may share your data among our corporate group companies. Alternatively, we may sell businesses or business units, merge with other entities, and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. As part of these transactions, we may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization in which SeedTrust participates, or to a purchaser or acquirer of all or a portion of SeedTrust’s assets, bankruptcy included.

Legal Obligations and Security

We will preserve or disclose your personal data in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant, or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person; to protect the safety or security of our Services or to prevent spam, abuse, or other malicious activity of actors with respect to the Services; or (iv) to protect our rights or property or the rights or property of those who use the Services.

If we are required to disclose personal data by law, such as pursuant to a subpoena, warrant, or other judicial or administrative order, our policy is to respond to legal mandates that are properly issued.

Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

Retention

We retain your personal data in accordance with your instructions, including those in the applicable terms of service accepted by you and any terms governing your use of the Platform and Services. We may also retain your personal data where we have an ongoing legitimate business purpose for doing so. We must retain information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, we retain the information as long as needed for exercising respective potential legal claims.

We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Services, and applicable legal requirements.

If you have questions about, or need further information concerning, our data retention periods, please send an email at [email protected].

Deletion

SeedTrust will delete personal data upon request unless deletion is prohibited by law. At SeedTrust’s option, we may delete personal data one year after our business relationship ends, subject to our document retention policies and practices. When we have no ongoing legitimate business purpose to process your personal data, we may either delete or anonymize it. Deletion may not be possible if your personal data was anonymized. In that case, the anonymized data will not be able to be combined with other data to identify you.

If you ask SeedTrust to delete specific personal data of yours, we will honor your request by deleting or anonymizing the data unless deleting that information prevents us from carrying out necessary business functions, such as delivering and billing for our services, managing active or future cases, calculating taxes, or conducting required audits and fulfilling contractual obligations to our Clients or others.

How you can control your data

Visitors and Clients who wish to request access to or correction of personal data for which SeedTrust is the data controller should send an email to [email protected].

How we keep your data safe

SeedTrust is responsible for SeedTrust’s compliance with and enforcement of this Privacy Policy. Our team is available to answer questions from any employees, Visitors, Clients, business partners, vendors, or others who may have questions concerning this Privacy Policy or SeedTrust’s data security practices. SeedTrust may be contacted at: [email protected].

Security

We cannot guarantee, ensure or warrant the security of any information transmitted to the Company. All transmissions of information are done at the sender’s own risk. Once we are in possession of information, we will make reasonable efforts to ensure the security of the information within our systems.

Your personal information and files are stored on SeedTrust’s servers and the servers of companies we hire to provide services to us.

SeedTrust has adopted physical, technological, and administrative procedures designed to safeguard and secure the information we process. By using this Site, Platform or Services or by providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Site, Platform or Services.

If you are a resident of Nevada, this entire Privacy Policy applies to you as well as the following. You may direct a business that operates an internet website not to sell certain personal information a business has collected or will collect about you.

SeedTrust does not sell your personal information pursuant to the definitions under Nevada law.

Acceptance

You agree that you have carefully read this document and agree to its contents. If you choose not to agree with this Privacy Policy, then you should refrain from using the Site, Services, and Platform.

SeedTrust reserves the right to change our Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will provide notice to you of these changes, which may be by email to you, by posting a notice of such changes on our apps and websites, or by other means consistent with applicable law. Unless your express consent is required by law, your continued use of the SeedTrust Site, Platform, and Services after having been notified of any such a revised Privacy Policy indicates acceptance of the revised Privacy Policy.

Contact Us

If you have questions, comments, or concerns about SeedTrust or this Privacy Policy, please email us at: [email protected].

SEEDTRUST ESCROW, LLC.
515 N. Flagler Drive, Suite P-300
West Palm Beach, FL 33401
Attn: Office of the General Counsel

 

Updated August 8, 2023