Privacy policy

Introduction

Protrition Labs LLC ("Protrition," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website at www.protritionlabs.com (the "Site"), request a quote, contact us, or otherwise interact with us in connection with our dietary supplement and nutraceutical contract-manufacturing services (collectively, the "Services").

We are a business-to-business contract manufacturer. Our Site is directed to businesses, brand owners, and professionals who are exploring or using manufacturing services. It is not directed to consumers purchasing finished products for personal use, and it is not directed to children.

Please read this Privacy Policy carefully. By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Site or submit information to us.

This Privacy Policy is incorporated into and subject to our Terms and Conditions.

Scope of This Policy

This Privacy Policy applies to information we collect:

• On or through the Site;
• In email, text, and other electronic communications between you and us;
• Through quote requests, contact forms, newsletter sign-ups, and similar Site features; and
• When you communicate with our sales, customer service, or business-development teams.

This Privacy Policy does not apply to information collected offline, through any channel other than the Site, or by any third party (including any third-party website, application, or service that may link to or be accessible from the Site).

Information We Collect

We collect several categories of information, depending on how you interact with us.

3.1 Information You Provide Directly

When you submit a contact or quote request, subscribe to communications, or otherwise correspond with us, we may collect:

• Your name and the name of the company or organization you represent;
• Your business title, role, or professional affiliation;
• Business contact details, including email address, telephone number, and mailing address;
• The contents of your inquiry, including product categories, target formulations, order volumes, timelines, and any other details you choose to share; and
• Any other information you voluntarily provide in messages, attachments, or forms.

3.2 Information Collected Automatically

When you use the Site, we and our service providers may automatically collect certain technical and usage information, including:

• Internet Protocol (IP) address and general location inferred from it;
• Browser type and version, operating system, and device identifiers;
• Referring and exit pages and the URLs that bring you to the Site;
• Pages viewed, links clicked, search terms entered on the Site, time spent on pages, and similar usage and interaction data; and
• Date and time stamps and other diagnostic data.

We collect this information using cookies, web beacons, pixels, log files, and similar technologies. For more detail, see our Cookie Policy and Section 7 below.

3.3 Information From Third Parties

We generally do not obtain personal information about you from third-party data brokers or lead-enrichment services. We may receive information that you submit through the third-party platforms we use to operate the Site (for example, our website forms and analytics providers), as described elsewhere in this Policy.

3.4 Sensitive Information

We do not seek to collect Social Security numbers, government identifiers, financial-account credentials, precise geolocation, biometric data, or other sensitive personal information through the Site. Please do not submit such information to us through the Site or by email.

3.5 Employment Applications and Recruiting

If you apply for employment, consulting, internship, contractor, or other opportunities with Protrition, we may collect personal information contained in employment applications, resumes, cover letters, references, interview notes, assessment materials, background information, and other information you choose to provide.

We may use this information to:

• Evaluate qualifications and suitability for available positions;
• Communicate with applicants regarding employment opportunities;
• Conduct recruiting, hiring, onboarding, and workforce-management activities;
• Verify information provided by applicants;
• Comply with applicable legal, regulatory, and employment-related obligations; and
• Protect our rights and interests in connection with recruiting and employment activities.

Applicant information may be retained for future employment opportunities unless prohibited by applicable law or requested otherwise by the applicant.

3.6 Health Information

Protrition is not a healthcare provider, health plan, or healthcare clearinghouse and is generally not subject to the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") with respect to information collected through the Site.

Users should not submit medical records, patient information, protected health information, treatment records, diagnostic information, or other healthcare-related information through the Site unless specifically requested pursuant to a separate written agreement.

Any health-related information voluntarily submitted through the Site will be treated in accordance with this Privacy Policy and applicable law.

How We Use Your Information

We use the information we collect for legitimate business purposes, including to:

• Respond to your inquiries, quote requests, and other communications;
• Evaluate, prepare, negotiate, and provide proposals and Services;
• Establish, administer, and service customer accounts and orders;
• Operate, maintain, secure, troubleshoot, and improve the Site and our Services;
• Understand how visitors use the Site and analyze trends and engagement;
• Send you administrative information, service updates, and, where permitted, marketing and promotional communications about our Services;
• Personalize and improve your experience and our marketing;
• Detect, prevent, investigate, and address fraud, security incidents, and other unlawful or harmful activity;
• Enforce our Terms and Conditions and other agreements; and
• Comply with applicable laws, regulations, legal processes, and our legal obligations.

We may aggregate or de-identify information so that it no longer reasonably identifies you, and we may use and disclose such aggregated or de-identified information for any lawful purpose.

4.1 Confidential Business Information

This Privacy Policy governs the collection, use, and disclosure of personal information. It does not modify, limit, supersede, or replace any confidentiality obligations arising under non-disclosure agreements, manufacturing agreements, quality agreements, supply agreements, product-development agreements, purchase orders, or other contracts entered into between Protrition and its customers, suppliers, vendors, or business partners.

Information relating to formulations, specifications, ingredient selections, product-development activities, manufacturing processes, testing data, quality records, regulatory submissions, forecasts, pricing, purchase orders, and similar business information may be subject to separate contractual confidentiality obligations.

5. International Visitors

The Site is intended primarily for users located within the United States.

Protrition does not intentionally direct the Site toward residents of the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions that impose separate privacy compliance obligations unless expressly agreed in writing.

Individuals who access the Site from outside the United States do so at their own initiative and are responsible for compliance with local laws.

By using the Site, you acknowledge that your information may be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction.

How We Disclose Your Information

We may disclose your information in the following circumstances:

• Service providers. We share information with vendors and service providers that perform functions on our behalf, such as website hosting, data storage, analytics, email and communications delivery, customer-relationship management, marketing support, and professional advisors. These parties are permitted to use the information only to provide services to us and are obligated to protect it.
• Analytics and marketing-platform providers. We use third-party analytics and customer-relationship/marketing platforms — currently HubSpot (which powers our website forms, email, and visitor analytics) and Cloudflare (which provides website delivery, security, and performance analytics) — that collect usage and device information on our behalf to help us understand and improve how visitors use the Site. These providers act as our service providers and are contractually limited to using the information only to provide services to us. We do not use this information for cross-context behavioral (targeted) advertising, and we do not sell or share personal information for targeted advertising as those terms are defined under state privacy laws.
• Affiliates. We may share information with our corporate affiliates for the purposes described in this Policy.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, information may be transferred as part of that transaction. We will seek to require the recipient to honor commitments consistent with this Policy.
• Legal and protective disclosures. We may disclose information when we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request; to enforce our agreements; to protect the rights, property, safety, or security of Protrition, our customers, or others; or to detect, prevent, or address fraud, security, or technical issues.
• With your direction or consent. We may share information at your request or with your consent.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising — including the personal information of any consumer under 18 years of age.

Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies to operate the Site, remember your preferences, analyze usage, and improve performance. You can control cookies through your browser settings and, where offered, through any cookie-preference tool on the Site. If you disable cookies, some features of the Site may not function properly.

For a fuller description of the cookies and tracking technologies we use and your choices, please see our separate Cookie Policy.

Do Not Track and Global Privacy Control. Some browsers transmit “Do Not Track” (DNT) or Global Privacy Control (GPC) signals. Because we do not sell or share personal information for targeted advertising, there is no sale or sharing to opt out of, and these signals do not change the limited analytics described in this Policy. If we begin selling or sharing personal information for targeted advertising in the future, we will treat a GPC signal as a valid opt-out and update this Policy.

Analytics

We use third-party analytics and marketing-platform services to understand how visitors use the Site and to operate our contact and quote forms. These services use cookies and similar technologies and may collect information such as your IP address, device and browser details, and on-site activity. The services we currently use are:

• HubSpot — powers our website forms, email communications, and visitor and marketing analytics. HubSpot processes this information as our service provider.
• Cloudflare — provides website delivery, security, and privacy-focused performance analytics.

We do not use advertising or retargeting pixels (such as Google Ads, Meta/Facebook, or LinkedIn advertising tags) on the Site, and we do not use these analytics tools for cross-context behavioral advertising. You can limit cookies through your browser settings and any cookie-preference tool on the Site, as described in our Cookie Policy.

If we add advertising or social-media pixels in the future, we will update this Section and our Cookie Policy, provide a “Do Not Sell or Share My Personal Information” opt-out, and honor Global Privacy Control signals.

Social media links. The Site links to our profiles on platforms such as LinkedIn and Instagram. If you click through, your activity on those platforms is governed by their own privacy policies. We do not embed third-party social-media tracking widgets that monitor your activity on the Site.

How We Protect Your Information

We maintain reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, misuse, destruction, or loss.

Our security measures may include:

• Role-based access controls;
• Authentication and authorization protocols;
• Encryption in transit where appropriate;
• Vendor-management and due-diligence procedures;
• Network monitoring and logging;
• Employee training and awareness programs;
• Incident-response and business-continuity procedures; and
• Periodic review and testing of security practices.

While we take reasonable precautions to protect information, no method of transmission over the internet or method of electronic storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

Users are responsible for maintaining the confidentiality of any account credentials and for using secure methods when communicating with us.

Your Privacy Rights

9.1 General Choices

You may:

• Update your information by contacting us at the address in Section 13.
• Opt out of marketing emails by using the "unsubscribe" link in any marketing message or by contacting us. We may still send you non-promotional, transactional, or service-related communications.
• Manage cookies through your browser settings and any available cookie tool.

9.2 Your U.S. State Privacy Rights

Depending on where you live, U.S. state privacy laws may give you certain rights regarding your personal information. These laws include the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and comprehensive privacy laws in states such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana, among others as they take effect.

Important note on business-to-business data. Although we are a business-to-business company, California's prior exemption for business-to-business contact information expired on January 1, 2023. As a result, personal information we collect from business representatives through the Site (such as your name, business email, and the contents of an inquiry) is generally covered by the CCPA/CPRA, and the California rights described in Section 9.5 apply to it. By contrast, several other state privacy laws (for example, those in Virginia, Colorado, Connecticut, and Utah) generally exclude personal information processed in a commercial (business-to-business) or employment context, which may limit how those laws apply to a B2B manufacturer.

Subject to the limits and exceptions in applicable law, these rights may include the right to:

• Know/Access the categories and specific pieces of personal information we have collected, the sources, the purposes for collecting it, and the categories of third parties to whom we disclose it;
• Correct inaccurate personal information;
• Delete personal information we have collected, subject to legal exceptions;
• Portability — obtain a copy of certain personal information in a portable format;
• Opt out of the "sale" or "sharing" of personal information and of targeted advertising and certain profiling; and
• Non-discrimination — not be discriminated against for exercising your rights.

Categories of information. Over the past twelve months, we may have collected the categories of personal information described in Section 3 (identifiers; professional or employment-related information; commercial information; internet or other electronic network activity; and inferences). We collect this information for the business purposes described in Section 4 and disclose it to the categories of recipients described in Section 6.

Sale/Sharing. We do not sell personal information, and we do not share personal information for cross-context behavioral (targeted) advertising, as those terms are defined under applicable state laws. Because we do not sell or share, there is nothing to opt out of; if this changes, we will provide a “Do Not Sell or Share My Personal Information” mechanism and honor opt-out preference signals such as Global Privacy Control.

9.3 How to Exercise Your Rights

To exercise any of these rights, you may submit a request through our data privacy request form, contact us by email at privacy@protritionlabs.com with “Privacy Request” in the subject line, or write to us by mail at the address in Section 13.

We will acknowledge and respond to your request within the timeframes required by applicable law. We will take reasonable steps to verify your identity before responding, which may require you to provide information we can match against our records, and we may decline or limit a request as permitted by law.

Authorized agents. You may use an authorized agent to submit a request on your behalf where the law allows. We may require the agent to provide proof of authorization and may require you to verify your identity directly with us.

Appeals. If we decline to act on your request and your state's law provides an appeal right (for example, in Virginia, Colorado, and Connecticut), you may appeal by contacting us at the email above. We will respond within the time the law requires. If your appeal is denied, you may have the right to contact your state attorney general.

Non-discrimination. We will not discriminate against you for exercising your privacy rights, including by denying services, charging different prices, or providing a different level or quality of service.

9.4 California "Shine the Light"

California Civil Code § 1798.83 permits California residents to request information about our disclosure of personal information to third parties for those parties' direct-marketing purposes. We do not currently disclose personal information to third parties for their own direct marketing.

9.5 Additional Disclosures for California Residents (CCPA/CPRA)

This Section provides additional information required by the CCPA/CPRA for California residents and supplements the rest of this Policy.

Categories of personal information we collect. In the preceding twelve months, we have collected or may collect the following statutory categories of personal information. We have not collected the categories marked "No."

Sources, purposes, and recipients. We collect these categories from the sources described in Section 3, use them for the business and commercial purposes described in Section 4, and disclose them to the categories of recipients described in Section 6. In the preceding twelve months, we may have disclosed identifiers, customer-records information, commercial information, internet activity, professional information, and inferences to our service providers and, where applicable, our affiliates and advisors, for those business purposes.

Sale and sharing of personal information. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. We have not sold or shared personal information in the preceding twelve months, and we do not sell or share the personal information of consumers under 18 years of age. If we begin to sell or share personal information for targeted advertising in the future, we will provide a “Do Not Sell or Share My Personal Information” link and honor Global Privacy Control signals.

Sensitive personal information. We do not collect or use sensitive personal information for purposes that would give rise to the right to limit its use. If this changes, we will update this Policy and provide a "Limit the Use of My Sensitive Personal Information" mechanism.

Your California rights. California residents have the rights to know/access, to delete, to correct, to opt out of sale/sharing, to limit the use of sensitive personal information, and to non-discrimination, as described in Sections 9.2 and 9.3. To exercise them, use the methods in Section 9.3.

Notice of financial incentives. We do not offer financial incentives or price or service differences in exchange for the collection, sale, or retention of personal information.

Metrics. We are not required to compile CCPA request metrics because we do not process the personal information of 10 million or more California residents in a calendar year.

9.6 Notice at Collection

At or before the point at which we collect personal information through the Site (for example, on a contact or quote form), we provide a brief “notice at collection” that identifies the categories of personal information collected, the purposes for which it is used, that we do not sell or share it for targeted advertising, and a link to this Policy.

9.7 Automated Decision-Making and Profiling

We do not use your personal information to make decisions that produce legal or similarly significant effects about you through solely automated processing without human involvement. We may use limited profiling for analytics as described in this Policy. Where applicable state law (including California's rules on automated decision-making technology) gives you rights to access information about, or to opt out of, certain profiling or automated decision-making, you may exercise those rights using the methods in Section 9.3.

Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide services, maintain business records, comply with legal obligations, resolve disputes, enforce agreements, and protect our legal rights.

Retention periods may vary depending on the nature of the information and applicable legal requirements. Examples of our general retention practices include:

We may retain information for longer periods when required by law, litigation holds, regulatory obligations, contractual requirements, audit purposes, fraud prevention, or other legitimate business needs.

When personal information is no longer required, we take reasonable steps to securely delete, anonymize, or otherwise render the information unreadable.

10.1 Security Incidents and Breach Notifications

In the event of a security incident involving personal information, Protrition will investigate the matter promptly and provide any notices required by applicable law.

Nothing in this Privacy Policy shall be construed as an admission that any particular incident constitutes a breach under applicable law.

Third-Party Links

The Site may contain links to third-party websites, services, or resources that we do not own or control. This Privacy Policy does not apply to those third parties, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party site you visit.

Children's Privacy

The Site is intended for businesses and adult professionals and is not directed to children. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a child under 18 without appropriate consent, we will take reasonable steps to delete it. If you believe a child has provided us with personal information, please contact us.

12.1 No Products or Services Directed to Minors

The Site is intended exclusively for business representatives, professionals, and adults involved in commercial purchasing, manufacturing, formulation, or related business activities.

We do not knowingly market products or services to children or minors.

How to Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us:

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Site, or applicable law. When we make changes, we will revise the "Last Updated" date above and post the updated Policy on the Site. If the changes are material, we will provide additional notice as required by law. Your continued use of the Site after the updated Policy is posted constitutes your acknowledgment of the changes to the extent permitted by law.

Governing Law

This Privacy Policy and any dispute arising out of or relating to it or the Site are governed by the laws of the State of New York, without regard to its conflict-of-laws principles, except to the extent that the privacy laws of your state of residence apply to your personal information.