Privacy and Cookie Policy

Last updated: 3 October 2026

This policy explains how Pons Medical Research LLC (“we”, “us”) collects and uses personal data when you visit surrogacybypons.com, write to us or contact us by phone or WhatsApp. We process personal data in line with the Law of Georgia on Personal Data Protection and, for visitors in the European Union and the European Economic Area, with the General Data Protection Regulation (GDPR).

1. Who is responsible for your data

Pons Medical Research LLC, 2/6 Lubliana St, Tbilisi 0159, Georgia. E-mail: [email protected]. Phone and WhatsApp: +995 574 83 22 58. For any question about your data, write to [email protected].

2. What data we collect

• When you use the contact form: your name, e-mail address, country, the topic you choose and your message. Your message may include information about your health or fertility. Please share only what is needed for us to answer you; we use it only to reply to your request.
• When you write to us by e-mail, phone or WhatsApp: your contact details and the content of the conversation.
• When you join a programme: the personal, medical and legal documents needed for the programme. These are covered by your contract and are not collected through this website.
• When you browse the website: technical data such as your IP address, browser, device and the pages you visit, which our server and our security provider record to keep the website working and secure. With your consent, also anonymous usage statistics (see section 6).

3. Why we use your data, and on what legal basis

• To answer your questions and prepare an offer: your request and steps you ask us to take before a contract (GDPR Art. 6(1)(b)); for health information you choose to share, your explicit consent (Art. 9(2)(a)), which you give with the checkbox of the form.
• To run the programme you sign up for: the contract (Art. 6(1)(b)) and, for health data, your explicit consent and the needs of medical care.
• To keep the website secure and protect it from spam and attacks: our legitimate interest (Art. 6(1)(f)).
• To measure how the website is used: your consent (Art. 6(1)(a)), which you can withdraw at any time.
• To comply with legal obligations, for example accounting and record-keeping: legal obligation (Art. 6(1)(c)).

We do not sell your data and we do not use it for advertising.

4. Who receives your data

• Service providers that work for us: our web hosting provider; Cloudflare, Inc. (content delivery, security and the Turnstile anti-spam check on the contact form); our e-mail provider; Google LLC, only if you accept statistics or external media (Google Analytics, Google Maps).
• WhatsApp (Meta Platforms), if you choose to contact us there; WhatsApp’s own privacy policy applies.
• Our partners in Tbilisi (the IVF clinic, the maternity house, notaries and lawyers) only when you join a programme and only the data they need for it.
• Public authorities, when the law requires it.

5. Transfers outside the European Union

We are based in Georgia, so data you send us is processed in Georgia. Some of our providers process data in other countries, including the United States. Where a transfer needs safeguards, we rely on the European Commission’s adequacy decisions (for example the EU–US Data Privacy Framework, for certified providers) or on standard contractual clauses; transfers that are necessary to answer your request or to perform your contract are also allowed by Art. 49(1)(b) GDPR.

6. Cookies and similar technologies

When you first visit the website we ask for your choice. Only necessary cookies are used until you decide, and you can change your choice at any time from “Cookie settings” at the bottom of every page.

• Necessary (always on): pons_consent stores your cookie choice (6 months); your browser remembers the language you chose; Cloudflare may set security cookies (for example __cf_bm) to protect the website from bots.
• Statistics (only with your consent): Google Analytics (_ga, _ga_*, up to 14 months) counts visits and pages in aggregate form. IP addresses are not stored by Google Analytics 4, and we do not use it for advertising.
• External media (only with your consent): the Google Maps map on the contact page. When it loads, Google receives your IP address and may set its own cookies.

7. How long we keep your data

• Enquiries and correspondence: up to 24 months after our last contact, unless you join a programme.
• Programme records: for as long as the programme lasts and afterwards for the period required by law.
• Website statistics: up to 14 months. Server and security logs: for a short period, normally a few weeks.

8. Your rights

You can ask us to access, correct or delete your data, to restrict or object to its use, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time, without affecting what was done before. To exercise your rights, write to [email protected]; we answer within one month.

You also have the right to lodge a complaint with a supervisory authority: in the European Union, the data protection authority of the country where you live or work; in Georgia, the Personal Data Protection Service.

9. Security

We protect your data with encrypted connections (HTTPS), access limited to the people who need it, and providers bound by confidentiality. No transmission over the internet is completely secure, so please do not send us sensitive documents through the contact form: we will tell you how to send them safely.

10. Minors

Our services are for adults. We do not knowingly collect data from people under 18.

11. Changes to this policy

We may update this policy when our services or the law change. The date at the top shows the latest version.