Privacy Policy

Surrogate Steps, LLC is committed in our efforts to maintain the privacy of individuals and describe the ways in which we may collect and use information. This Privacy Policy informs you of the information we may collect when you visit or interact with our website or business and how we may use this information. 

Surrogate Steps aims to match Gestational Carriers with Intended Parents who have contacted our business to help them have a child. In our efforts to attract, screen, and match Intended Parents with Gestational Carriers, we may obtain information from visitors when they visit our website or engage our business. Information may be collected from individuals online, by mail, by telephone, or in person.

By using our website, you signify your acceptance of this Privacy Policy. You should not use our website if you disagree with this Privacy Policy. Your continued use of our website after posting changes to this Privacy Policy will mean that you accept those changes.

Changes to our Privacy Policy

Surrogate Steps reserves the right to change this Policy at any time and will post any changes to it as soon as they go into effect on this webpage. The Notice was last updated on April 7th, 2023. Your continued use of our website after posting changes to this Privacy Policy will mean that you accept those changes.

Information We Collect

Surrogate Steps collects information on our website via two primary methods.

  1. Automatic Data Collection: When you use our website, we may collect “Non-Personal Information.” Non-Personal Information is information that, by itself, cannot be used to identify or contact you, such as demographic information or technical information regarding your web access. For example, Non-Personal Information may include your age, gender, income, education, profession, ZIP code, IP address, the type of browser you are using, the websites you visit immediately before and immediately after you visit our website, and other anonymous data involving your use of our website. Non-Personal Information may also include information that you provide us through your use of our website, like the terms you enter into the search functions of our website.


  2. Data Disclosed By You:At various locations on our website, such as in registration forms, contact forms, application forms, applications profiles, surveys, and consultation requests, Surrogate Steps may request that you supply us with personal information, such as your name, email address, mailing and shipping addresses, telephone number, your health and family health, employment information, and more. Although you do not have to provide us with any information to visit our website, you may not be able to fully utilize all of the services on our website if you choose not to provide certain information. If you do choose to give us personal information through our website, we will collect and retain that information.


A “cookie” is a text file that a website inserts into the browser files on your computer. A website might send your browser “cookies,” which are little data files that are stored on your computer. Cookies do not include any personal data about you (unless you knowingly provide it). Cookies can record the date and time that your browser visited particular websites, pages, or advertising. Cookies are used by Surrogate Steps to improve the performance and navigation of our website, to confirm your identification, to target adverts, and to personalize various parts of your visit.

To use and access our website, you do not need to accept cookies. Most web browsers can be configured to inform you when a cookie is being stored on your computer or to refuse all cookies, despite the fact that accepting cookies is their default setting. But, your Internet experience may be impacted if you refuse to accept cookies. Existing cookies on your machine can be deleted. See the Help section of your specific browser and operating system software for further information on managing cookies.

How We Use the Information We Collect

  1. Services: Your Personal Information is used by us to fulfill your service requests, communicate with you, and enable your participation in our online applications, consults requests, and other forms. 
  2. Email Communications: If you send us an email with questions or comments, we might use your personal information to get back to you and we might also save your email for future use. We may email you in order to communicate with you regarding gestational carriers and intended parents, to offer customer support in relation to these services, and in order to share information with you regarding additional services that we think you might find interesting.
  3. Business and Marketing: In order to better understand the demographics of our clients, we collect and analyze aggregated Non-Personal Information about them, such as the age, sex, and location of our users as well as other demographic information. We use the non-personal information we gather to better understand how people use our website and online services and for marketing and promotional initiatives, including retargetting campaigns that serve advertisements to individuals who visit certain pages or combination of pages on our website.

Non-Identifying Information

Information that cannot be used to identify a specific person, such as age, race, ethnicity, height, weight, etc., is referred to as non-identifying information. In order to ascertain whether a match between the two parties is feasible, Surrogate Steps will provide this non-identifying information to Gestational Carriers who have registered to take part in the gestational carrier program. Moreover, non-identifying data may be provided to: 

i) third parties as necessary for our regular business operations to match possible gestational carriers

ii) internally for auditing, demographic analysis, and similar objectives, or iii) for any legitimate reason.

In this regard, no personal or identifying information that could be used to directly identify a person would be disclosed.

Identifying Information

Any information that can be used to specifically identify a person, such as a name, social security number, address, phone number, etc., is referred to as identifying information. When needed as the gestational carrier process develops, Surrogate Steps will collect identifying information from people taking part in the program from gestational carriers. Except as specified below, Surrogate Steps will not divulge personally identifying information to the general public:

  • As Required by Law: When required to do so by law, Surrogate Steps may use and disclose your identifying information. This includes, but is not limited to, a response to any judicial order, subpoena, summons, warrant, discovery request, or similar legal request and/or administrative proceedings; a response to a request for information from law enforcement; and a warning to law enforcement of any criminal activity on the property of Surrogate Steps or of any fatality that may result from said criminal activity. Also, in order to fulfill government-mandated reporting requirements, identifying information may be revealed.
  • Coordination of Health Care: In order to coordinate medically related activities between your primary doctor, any consultants, and any other medical personnel who may need such identifying information in order to ensure your proper care and treatment in addition to any legal obligations, Surrogate Steps may use and disclose your identifying information.
  • Public Safety: If Surrogate Steps determines that it is reasonable to believe that disclosure is necessary to either minimize or avoid an impending risk to an individual’s health and/or safety or the safety of the community, we may use or disclose your personal information. Your identifying information may be used and/or disclosed by Surrogate Steps as necessary to support day-to-day operations and management of Surrogate Steps. Such activities comprise, but are not limited to, the evaluation of service quality, support for auditing and/or accounting, licensing, IT systems, and legal assistance.
  • Business Associates: Some of Surrogate Step’s services call for the engagement of outside service providers. Your identifying information may only be disclosed by Surrogate Steps to the aforementioned service providers insofar as it’s necessary for them to carry out the work for which they have been hired and as permitted by law. All of our business partners must take great care to protect the confidentiality of your identifiable information.
  • Marketing: Surrogate Steps may contact you about emerging technology, services, and/or complementary therapies that Surrogate Steps thinks may benefit you.
  • Other: Your identifiable information may be used and disclosed by Surrogate Steps for any legal purposes at its discretion. Surrogate Steps cannot guarantee that identifiable information won’t be disclosed without our knowledge due to the rapid advancements in technology, computer science, and the internet. Nevertheless, Surrogate Steps will try to keep your identifying information secure and secret.

Surrogate Steps only collects identifying data from web visitors who freely provide it. 


Our website, along with any products and services Surrogate Steps offers, are all directed to people who are at least 18 years of age. Users under the age of 18 are not the target audience for this website or business. We advise users under the age of 18 not to provide us with any information, and Surrogate Steps does not knowingly collect personally identifiable information (“Personal Information”) from anybody we know to be under the age of 18. If you believe we might have received information from someone under the age of 18, please contact us at 

Non-US Users; Users from the European economic area

Laws governing privacy and what is expected of citizens differ by nation. Please be aware that if you access our website from outside the United States, you consent to the transfer of your information to the United States as well as the collection and processing of that information there. The rules in the United States governing the gathering, using, disclosing, and processing of information may be different from those in other nations and may be less strict than the laws that apply in your jurisdiction. You authorize any transmission and processing of your personal data in accordance with this Privacy Policy by giving us your personal information.

Please take note of the following if you are in the European Economic Area (“EEA”):

Individual data rights: Under European law, people from the EEA have specific rights with regard to their personal data. These rights include the opportunity to request access to, rectify, update, delete, object to or limit the use of, or request data portability for their personal data. Please contact us at if you want to exercise these rights.

Legal basis: For individuals residing in the EEA, we point out that we act as a data controller when we collect your personal information. We use it to further the aforementioned legitimate business interests, as well as our legitimate consents (such as when you provide us with registration information or enter into a contract with us to use our service) (such as to support direct marketing efforts). Please contact us using the details provided below if you want to revoke previously given consent. We suggest that you refer to the contract if you have a contract with us to understand your rights and obligations. Please contact us using the details provided below if you think your personal information has been used in a way that does not comply with the pertinent privacy policies indicated above. You have the right to file a complaint with the appropriate supervisory authority in the member state where you reside over our data practices.

Data Retention: For people in the EEA, our policy is to store your personal data as follows: for those requesting education about our service information or applying for our service, we will retain your personal data for up to 3 years; for people who engage in our screening and review processes, we will retain your information for up to 7 years as we have observed that significant decisions like this typically take a number of years. If you choose to use our service, we will keep your personal information on file until you tell us to delete it since we provide continuing service, contact, medical care, and legal assistance for the duration of your future children’s life.  If necessary to comply with ongoing contractual obligations, legal procedure retention requirements, health regulations, or other mandatory operational or similar audit requirements, we may keep your information after these retention periods have passed until you cancel your account.

By phoning us, you may always request your information or make changes to it.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) gives Californians new rights as consumers with regard to accessing, erasing, and disclosing personally identifiable information that businesses have acquired about them. Consumers in California have the following rights under this law: • Request that personal information stored by businesses be erased; • Opt out of the sale of personal information. Consumers have the right to know how their personal information is acquired, utilized, shared, or sold.

Here, you can find out more.

Your information is always subject to request or alteration.

Third-Party Links

For the convenience of our clients and web visitors, we may include links to other websites. Surrogate Steps is not liable for the accuracy or reliability of any data, products, information, or methods found on these websites. Third-party sites have separate and independent privacy policies and are operated by other entities. The privacy practices, or lack thereof, of any connected websites are not the responsibility of Surrogate Steps.

Contact Us

Please contact us by email if you believe that Surrogate Steps has ever violated the guidelines established in this privacy statement. We will then make all commercially reasonable attempts to ascertain the issue and remedy it as soon as possible.

Please get in touch with Surrogate Steps at: if you have any inquiries regarding this policy.

Surrogate Steps, LLC

10319 Westlake Dr #485

Bethesda, MD 20817

(202) 802-0257

This Privacy Policy is effective as of 2023. Surrogate Steps reserves the right to change this Policy at any time and will post any changes to it as soon as they go into effect.


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