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Militta IVF Agency
Legal

Privacy Policy

Last updated: April 19, 2026. Effective date: April 19, 2026.

1. Who we are

“Militta” (also referred to as “we”, “us” or the “Agency”) operates the website militta-sur.com and provides IVF and surrogacy agency services.

Data controller: Militta IVF Agency. Contact for privacy inquiries: privacy@militta-sur.com.

2. What personal data we collect

When you submit our consultation or contact forms, we collect:

  • Full name.
  • Email address.
  • Phone number (optional).
  • Country of residence (optional).
  • Destination of interest (optional).
  • The free-text message you provide.
  • Technical metadata we receive automatically: your IP address, browser user-agent, and the referring URL. This is used for security and abuse prevention only.

We do not collect special categories of data (health data, biometric data, sexual orientation) through this website. Such data may be collected later, only with your explicit consent, as part of an engagement agreement during active case management.

3. Why we collect it (lawful basis)

The lawful bases under the EU GDPR and the UK GDPR are:

  • Consent (Art. 6(1)(a)): you submit a form to request information or a consultation.
  • Performance of a contract (Art. 6(1)(b)): once you engage us, we process your data to deliver the program.
  • Legitimate interests (Art. 6(1)(f)): basic server logs for security, fraud prevention and ensuring the website operates correctly.

4. How we use your data

  • To respond to your inquiry and schedule a consultation.
  • To send your request to our internal case-manager team via a private Telegram workspace restricted to authorised Militta staff.
  • To retain a record of the inquiry for legitimate follow-up (typically 24 months).
  • To improve our service. We do not use your data for advertising, profiling or any automated decision-making.

5. Who we share your data with

We share your data only with the following categories of recipients, and only to the minimum extent necessary:

  • Militta's own case-manager team (bound by confidentiality agreements).
  • Once you engage us and only with your informed consent: selected partner clinics, independent attorneys, notaries, escrow agents and embassies as required to deliver the program.
  • Sub-processors operating the website infrastructure (hosting, email delivery) — all contracted under GDPR-compliant Data Processing Agreements.
  • Telegram LLC — used exclusively as an internal notification channel for new inquiries. Message content is limited to the fields you submitted plus technical metadata.
  • Google LLC (Google Analytics via Google Tag Manager) — aggregated, anonymised traffic analytics only. See our cookie notice for the specific cookies set and their purpose.
  • Google LLC (reCAPTCHA v2) — to protect our forms from automated abuse; processes your token and IP address for spam verification purposes only.

We do not sell your personal data. We do not share your data with advertising networks, data brokers or any third party outside the narrow use above.

6. International transfers

Militta is headquartered in Ukraine. If you are in the EEA, UK or Switzerland, your data may be transferred to Ukraine, which has been recognised by the European Commission as providing an adequate level of data protection (Commission Adequacy Decision). Where additional transfers occur, we use Standard Contractual Clauses or equivalent safeguards.

7. How long we keep your data

  • Inquiry data (forms): up to 24 months from last contact.
  • Engagement data (once you sign a contract): for the duration of the program plus 10 years (standard commercial and medical record-keeping obligations).
  • Technical server logs: up to 90 days.

8. Your rights

Under the GDPR, UK GDPR and similar laws, you have the right to:

  • Access the personal data we hold about you.
  • Rectify inaccurate data.
  • Request erasure (“right to be forgotten”).
  • Restrict or object to processing.
  • Data portability.
  • Withdraw consent at any time, without affecting the lawfulness of processing already carried out.
  • Lodge a complaint with your national supervisory authority.

To exercise any of these rights, email privacy@militta-sur.com. We respond within 30 days.

9. Cookies

We use the minimum set of cookies necessary to operate the website. We do not run analytics, advertising, pixels or tracking scripts by default.

See our cookie notice for the full list.

10. Security

All form submissions are transmitted over HTTPS/TLS. Access to internal case records is limited to named Militta personnel and protected by strong authentication. We document a security incident response plan and will notify affected users within 72 hours of becoming aware of any personal-data breach, as required by Art. 33 GDPR.

11. Children

Our services are directed at adult intended parents, donors and surrogates (18+). We do not knowingly collect personal data from persons under 18. If you believe a minor has provided us data, contact us for immediate deletion.

12. Changes

We may update this Privacy Policy. Material changes will be notified via a banner on the website and, for active clients, by email.

13. Contact

Email: privacy@militta-sur.com
Postal: Militta IVF Agency, Kyiv, Ukraine (exact address provided upon request).