References to “we”, “us” or “our” means CooperSurgical, Inc., and may also include our affiliates listed below.
References to “you” and “your” relates to data subjects.

This Privacy Policy outlines when, why and how we collect, use and otherwise handle (collectively “process“) personal data about users of our Portal.

“Personal Data” is any information relating to you, which can be used to personally identify you, either directly or indirectly.

We provide the Portal to clinics and hospitals (Customers) (including for use by their employees / personnel.

We offer a range of services, including those related to, but not limited to, providing a wide range of medical solutions, billing services, pre-implementation genetic services and testing. We refer to all these services collectively, together with any other CooperSurgical products, as “Services” in this Privacy Policy.

We may process your Personal Data, as described in this Privacy Policy and as described when we collect data from you. Our Privacy Policy must be read together with any other legal notices or terms and conditions provided to you when we collect data from you (or at a later stage) or that are available on other pages of our website.

We take your privacy very seriously and ask that you read this Privacy Policy carefully, as it contains important information about our processing of your Personal Data and your rights.

We may change this Privacy Policy from time to time. A current version is available on the Portal. Please visit the Portal regularly and inform yourself about the applicable data protection provisions.

B. WHO IS ACCOUNTABLE FOR YOUR DATA?

We, CooperSurgical are the data controller of your Personal Data. We can be contacted at [email protected].

Where CooperSurgical shares personal data with CooperSurgical Affiliates (Affiliates, which means our subsidiaries, our ultimate holding company and its subsidiaries), the Affiliates are also data controllers as explained in this Privacy Policy. Details of the Affiliates, including their locations, are listed below.

C. WHAT DATA DO WE PROCESS AND WHY?

The types of information that we may process about you, and the purposes of processing, include:

Type of information	Purposes of processing	Legal basis of processing
Your name Your (business) email address Your organization details Unique user ID Your service region MFA tokens User terms and conditions acknowledgement log Your username or login name Your password Your device’s IP address Information about the operating system or app you are using Your unique device identifiers Your online identifiers Website visit information Your preferences and settings Your location information collected by a browser or inferred by IP addresses, mobile device signals Your Internet Service Provider and top-level domain name	To provide, operate and secure the Platform Authenticate users and enable secure access to connected applications Enforce multi factor authentication for enhanced security Maintain audit logs for compliance and security monitoring To perform our obligations under our agreements with our Customers To administer our systems To communicate with you, send you non-marketing materials To conduct marketing activities To contact you about our Company, Services or other news Review, develop and improve the Platform To personalize your experience with us To enable your use of our Services To identify where you are contacting us from To measure certain traffic patterns on our website, such as the number of visits, average time spent on the website, pages viewed, etc. To conduct aggregated statistical analyses To link your profile on a third-party site or platform with any account(s) with us Internal business purposes (see below this table for further information)	Where we need to comply with a legal or regulatory obligation under and in accordance with any applicable national, international, federal, state laws and/or regulations (“Compliance with Law”) Where it is necessary for our pursuit of legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”) Your consent (If requested and provided)

Our business purposes – we may also use your Personal Data for our internal business purposes such as:

complying with applicable laws, lawful requests, and legal process (such as to respond to disclosure orders or similar, as well as investigations or requests from government authorities);
record keeping, statistical analysis, internal reporting;
to host, maintain and otherwise support the operation of our websites, applications and other communication platforms, including to customize various aspects of our websites, applications and other platforms to improve your experience;
to perform marketing analytics and business improvement;
detecting, preventing and addressing technical issues;
to investigate, resolve or otherwise address any complaints you make;
to provide evidence in any disputes or anticipated disputes between you, your patients and us;
for the detection and prevention of fraud, other criminal offences and for risk management purposes;
for business and disaster recovery (e.g., to create back-ups);
to ensure network and information security;
for data retention/storage;
to protect the rights, property, and/or safety of CooperSurgical, Inc., any of its Affiliates, its personnel and others; and

No obligation to provide Personal Data. You do not have to provide Personal Data to us. However, where we need to process your Personal Data either to comply with applicable law or to deliver our Platform, and you fail to do so where required, we may not be able to provide some or all parts of our Platform.

D. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

a) Data sharing with other CooperSurgical Affiliates

We may share your Personal Data with our Affiliates:

where we need to do so in order to provide the Services or information that you have requested; or
for the purposes of IT support and maintenance; or
for the purposes of supporting marketing operations and conducting marketing activities; or
internal governance and administration; or
to comply with our legal or regulatory obligations.

b) Data sharing with service providers

We also share your Personal Data with our third-party service providers, whom we engage to provide various services, which include but are not limited to:

Website services (e.g., hosting and maintaining our websites); and
IT services and solutions (e.g., providing data storage, assisting us with database management).

c) Data sharing with other recipients

We may also share your Personal Data with:

your organization for legitimate business purposes (e.g., provision of services);
our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of CooperSurgical, any of the Affiliates, its personnel and others;
any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation; or
Law enforcement agencies in connection with the prevention and detection of crime.

E. INTERNATIONAL TRANSFERS OF PERSONAL DATA

We and our Affiliates are located in various countries worldwide. We may also use third party suppliers located outside the EEA and the UK. Those of you located in the EEA or the UK may have your Personal Data transferred outside the EEA and the UK to countries such as the United States, where it will be stored and processed for the purposes set out in this Privacy Policy. Where we transfer personal data outside of the UK and/or EEA we will implement appropriate and suitable safeguards to ensure that such personal data will be protected as required by applicable data protection law. For example, where your personal data is transferred to CooperSurgical Affiliates, the safeguards which we typically put in place are the European Standard Contractual Clauses and UK Addendum, as applicable, and as permitted by data protection law.

You can request further details about the safeguards that we have in place in respect of transfers of Personal Data outside of the EEA and/or UK by contacting us at: [email protected].

F. HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with our Customers). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including:

legal obligation(s) under applicable law to retain data for a certain period of time (e.g., compliance with regulatory requirements);
the establishment, exercise or defence of legal claims (e.g., for the purposes of a potential dispute).

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at: [email protected].

G. HOW DO WE PROTECT YOUR PERSONAL DATA?

We have implemented technological and operational security measures in order to protect your Personal Data from loss, misuse, or unauthorized alteration or destruction. Such measures include the use of firewalls, encryption (where appropriate), proper access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data. Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

H. YOUR RIGHTS

You have certain rights in relation to the Personal Data we hold about you. The rights may only apply in certain circumstances and are subject to certain exemptions. Depending on the circumstances, you may have the following rights under applicable data protection law with respect to your Personal Data and our processing of that data. If you would like to exercise any of these rights, please contact our data protection officer at: [email protected]. Please allow up to 30 days to fulfil your request. We can extend this period in accordance with applicable privacy laws.

The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Privacy Policy and in any legal notices or terms and conditions provided to you.
The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about certain other information (similar to that provided in this Privacy Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of the Personal Data concerning you. We can refuse to provide information where to do so may reveal Personal Data about another person or would otherwise negatively impact another person’s rights.
The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you). If we have shared your Personal Data with others, we’ll let them know about the rectification where possible.
The right to erasure – this is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g. where we need to use the information in defence of a legal claim or to be able to comply with a legal obligation.
The right to restrict processing – you have the right to suspend the use of your Personal Data. For example, when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further. If we’ve shared your Personal Data with others, we’ll let them know about the restriction where it is possible for us to do so.
The right to data portability – you have the right to receive from us certain Personal Data. This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format or (where technically feasible) we may transmit your Personal Data directly to a separate data controller.
The right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defence of legal claims.
The right to withdraw consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
The right not to be subject to decisions based on automated processing – you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, except where permitted by applicable law.
The right to lodge a complaint with the supervisory authority – You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law.

I. STATE PRIVACY RIGHTS

This section provides additional information to residents of particular states pursuant to applicable state privacy laws (collectively the “State Privacy Laws”). In this section, the term “Personal Information” means information defined as “personal information,” “personal data,” or other similar term under the State Privacy Laws. The State Privacy Laws may provide residents with some or all of the rights listed below. Please note that not all rights listed below may be afforded to all data subjects and that if you are not a resident of one of the states that provides for such rights, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. We may decline your request in certain cases as permitted by law. The below may be dependant upon whether your state of residency requires us to do the following:

Information. You can request the following information about how we have collected and used your Personal Information:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you .
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us, subject to certain exceptions, to delete the Personal Information that we have collected from you.
Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
Limit processing of sensitive Personal Information. You can request to limit the processing of any sensitive Personal Information collected.
Non-discrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to information/know, access, appeal, correction, deletion and limit processing of sensitive Personal Information. You may submit requests to exercise your right to information/know, access, appeal, correction, deletion or limit processing by contacting us at: [email protected].

J. COOKIES

We use only strictly necessary cookies that are required for the secure operation of the Portal and related services. These cookies are primarily provided through our authentication system, and are used to maintain user sessions, support login and authentication processes, enable multi-factor authentication (MFA), and ensure secure access to user accounts and Portal functionality.
These cookies are essential for the website to function properly and cannot be switched off through our systems. We do not use cookies or similar technologies for advertising, marketing, profiling, or user tracking purposes. No information collected through these necessary cookies is used to monitor your browsing activities outside the Website or to build user profiles.

K. USE OF ELECTRONIC COMMUNICATIONS AND RIGHT TO OPT OUT

We may occasionally send you email or contact you by phone about Services that we feel may be of interest to you, or that you have requested. We offer recipients the opportunity to opt out of future marketing communications via our marketing emails or via direct requests. You have the right to opt out of these marketing emails by selecting the “unsubscribe from all future emails” link in the marketing emails we send you or by directly requesting from us at [email protected].

Please note that we may not allow an opt-out option for non-marketing Service emails (for example, emails concerning your privacy policy updates or Service/platform use etc.).

L. THIRD PARTY LINKS

Our Websites, Privacy Policy, and/or Website terms and conditions may contain links to websites that are not operated by CooperSurgical. Please be aware that we are not responsible for the privacy practices of these sites nor for any adverse consequences that may result from your interaction with such third-party websites. Just because we link to, receive data from, or partner with a particular site or app does not mean that we endorse it or its privacy practices. These other websites and apps have their own terms of use and privacy policies; we encourage you to read those terms and policies when you visit those websites and use those apps.

M. HOW TO CONTACT US

If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Data, contact our Data Protection Officer at: [email protected]

N. COOPERSURGICAL GROUP

California Cryobank LLC (company number 5901958) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
California Cryobank Stem Cell Services LLC (company number 5901963) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
CBR Systems, Inc. (company number 5068343) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Cell Care Australia Pty. Ltd (company number 110312537) with its registered address at 42 Corporate Drive, Heatherton, Victoria 3202.
Cooper Medical, Inc. (company number 35-2440228) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
CooperGenomics, Inc. (company number 81-5078002) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
CooperMedical S.r.l. (company number 3102732110) with its registered address at Escazu, Plaza Roble Corporate Center, Los Balcones Building, Fourth Floor, San Jose, Costa Rica.
CooperSurgical (Shanghai) Co. Ltd. (company number 10000002201912000000) with its registered address at Suite 1508, No 889 Wanhangdu Road, JingAn District, Shanghai 200042.
CooperSurgical Canada Inc. (company number 3320226) with its registered address at McInnes Cooper, 1300-1969 Upper Water Street, Purdy’s Wharf Tower II, Halifax NS B3J 2V1, Canada.
CooperSurgical Distribution B.V. (company number 71752188) with its registered address at Celsiusweg 35, 5928PR, Venlo, Netherlands, Netherlands.
CooperSurgical Malaysia Sdn Bhd (company number 1327875-D) with its registered address at Suite 50-1-11, 12 & 13, Level 1, Wisma UOA Damansara, No. 50, Jalan Dungun, Damansara Heights, 50490 Kuala Lumpur, Malaysia.
CooperSurgical Origio Pte. Ltd. company number 201631426E) with its registered address at 8 Temasek Boulevard, #19-03, Suntec Tower 3, 038988, Singapore.
CooperSurgical, Inc. (company number 94-3132521) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
DEB Donor Egg Bank Canada Ltd (company number BC1268358) with its main office address at 108A – 175 Longwood Rd S, Hamilton, ON L8P 0A1, Canada.
Donor Application LLC (company number 7621781) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Generate Life Sciences, Inc. (company number 6896672) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Generate Sperm Bank Canada Ltd. (company number BC1268360) with its main office address at 108A – 175 Longwood Rd S, Hamilton, ON L8P 0A1, Canada.
Genesis Genetics Canada Inc. (company number 3320229) with its registered address at 1969 Upper Water Street, Suite 1300, Purdy’s Wharf Tower II, Halifix NS B3J 3R7, Canada.
Insception Biosciences, Inc. (company number BC1316459) with its main office address at 1620 Tech Ave Unit #1, Mississauga, ON L4W 5P4, Canada.
Invitro Genetics Limited (company number 9901425) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, United Kingdom.
Invitro Genetics, LLC (company number 81-5454415) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Leisegang Feinmechanik Optik GmbH (company number HRB 4064) with its registered address at 32, D-10625, Berlin, Germany.
LifeGlobal Group, LLC (company number 1277670) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Medek Medikal Ürünler ve Sağlık Hizmetleri A.Ş (company number 420618) with its registered address at Suadiye Mahallesi Bagdat Caddesi , No:417, Daire:9 , Kadikoy, Istanbul, Turkey.
OBP Medical Corporation (company number 26-1128220) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Origio A/S (company number 10975077) with its main office address at Knardrupvej 2, 2760, Malov, Denmark.
Origio A/S, Dubai Branch (company number 1132) with its registered address at 26, Dubai Healthcare City, Floor 6, Office 606, Dubai, United Arab Emirates.
Origio Australasia Pty Ltd (company number 111 964 106) with its registered address at Unit 31, 7 Sefton Road, Thornleigh NSW 2120, Australia.
Origio Benelux B.V. (company number 34246551) with its registered address at Celsiusweg 35, 5928PR, Venlo, Netherlands, Netherlands.
Origio Cooper LLC (company number 1157847453092) with its registered address at Pulkovskoe shosse 40, block 4, litter A, 196158, St. Petersburg, Russian Federation.
Origio France S.a.r.l. (company number 417 650 637) with its registered address at 93 Rue de Chantier, 78000, Versailles, France.
Origio GmbH (company number HRB 69804) with its registered address at Hildegardstr. 31, 10715, Berlin, Germany.
Origio India Pvt. Ltd. (company number U24230MH2005PTC155098) with its registered address at C-401 Delphi, Hirandani Business Park, Mumbai, 400076, India.
Origio Italia srl (company number 5559430482) with its registered address at Viale Shakespeare 47, int. 2/a, 00144, Roma, Italy
Origio Japan K.K. (company number 0200-01-095667) with its registered address at Yokohama Media & Communication Center, 4F Nihon-Odori 11, Naka-ku, Yokohama, Kanagawa, 231-0021, Japan.
Origio Limited (company number 3221787) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, United Kingdom.
Origio LLC company number 1107847205003) with its registered address at Pulkovskoe shosse 40, block 4, litter A, 196158, St. Petersburg, Russian Federation.
Origio Medicult Espana s.l. (company number 7A3309838) with its registered address at Moll de Barcelona s/nº. Edificio Nord, Pl. 4ª, módulos 414-415, 08039, Barcelona, Spain.
Recombine, LLC (company number 38-4028993) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Reprogenetics, LLC (company number 47-2020915) with its registered address at c/o Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808, United States.
Research Instruments Limited (company number 3419143) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, United Kingdom.
Safe Obstetric Systems Ltd. (company number 5923369) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, United Kingdom

EFFECTIVE DATE: August 2026