Privacy Policy

Effective Date: July 9, 2026
Last Updated: July 9, 2026

1. Introduction

ProCircular, Inc. (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy and handling your information transparently and securely. This Privacy Policy (the “Policy”) describes how we collect, use, disclose, and safeguard your personal information when you visit our website (the “Site”), communicate with us, or engage with our products or services in any way. By interacting with the Site or our products or services in any way, including communications with our salespeople, you hereby consent to the terms of this Policy.

2. Information We Collect

a. Information We Collect Automatically

When you visit the Site or interact with our products and services in any way, including any communications with our salespeople, we collect some information automatically.

i. Cookies

The Site uses cookies, which are small text files that are placed on your machine to help the Site provide a better user experience. In general, cookies are used to retain user preferences, store information for things such as shopping carts, and provide anonymized tracking data to third-party applications such as Google Analytics. Generally, cookies will make your browsing experience better.

You can disable cookies by changing the preference settings in your web browser.

ii. Usage and Session Information

We automatically track your activity on the Site, including the URL of the website from which you came to the Site, which browser or device type you used to access the Site, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on the Site. We may capture the screen images that you view or collect information about how you interact with screens on the Site with your keyboard, mouse, or other input device. We also collect information about what products and services you browse, search for, or otherwise express an interest in, and we track your activity on the Site and other websites where we advertise.

We collect and use such information to evaluate the effectiveness of our marketing and advertising, to troubleshoot and improve our products and services, to provide customized marketing and advertising messages, to customize advertising, and to personalize and improve your user experience on the Site.

iii. Transaction and Purchase Information

When you make a purchase or conduct a financial transaction with us, we collect information about the purchase or transaction. This may include, but is not limited to, product or service details, purchase price, date, tender type, location of the transaction, any shipping or delivery details, and payment type and payment authorization.

b. Information You Provide to Us

We collect and maintain information that you provide to us through your use of our products and services and by interacting with our products and services, including any communications with our salespeople. We collect personal information from employees, contractors, vendors, clients, and other individuals necessary for business operations.

i. Contact Information

We collect your name, company address, billing address, telephone number(s), and email address(es).

ii. Payment Information

If you make a purchase or conduct a financial transaction with us, we collect payment card numbers, financial account information, billing address, and other payment details.

c. Client and Service Data

In the course of providing our products and services, we may process data provided by clients, which may include sensitive or confidential information, such as personally identifiable information (PII) and protected health information (PHI). Such data is governed primarily by applicable client agreements in addition to this Policy.

4. How We Use Your Information and Data

We use collected information for legitimate business purposes, including, but not limited to, (1) responding to inquiries and providing requested services; (2) operating, maintaining, and improving the Site and our products and services, (3) communicating with you about updates, products and services, and relevant information; (4) ensuring security, monitoring for threats, and preventing fraud or misuse; and (5) complying with legal, contractual, and regulatory obligations.

a. Sending and Improving Marketing Communications

We may send you communications about promotions or offers via regular mail, email, text messaging, or other electronic channels, including ads on social media and other websites. We may use the information we collect for marketing and analytics purposes and to deliver marketing communications based on your behavior and interests.

b. Compliance

We use your data to fulfill our legal, contractual, and regulatory obligations and requirements, including tax and reporting obligations.

c. Internal Artificial Intelligence (“AI”) and Business Operations Use

We may use and process information, including personal information, for internal research, development, and operational purposes, including, but not limited to: (1) training, testing, and improving internal Company artificial intelligence, machine learning, and analytical models; (2) enhancing cybersecurity methodologies, threat detection capabilities, and service delivery, and (3) conducting internal Company analytics, quality assurance, and business intelligence activities.

5. Information Sharing

We do not sell your personal information. We may share your personal information with the following parties, as needed:

• Service Providers and Vendors: Third-party vendors and partners who assist us in delivering services, managing operations, or fulfilling legal obligations.
• Affiliates and Subsidiaries: Other entities within our corporate group for business purposes.
• Legal and Regulatory Authorities: When required by law or to protect our legal rights and interests.
• Business Partners: With your consent or as necessary for specific business collaborations.
• Third-Party Marketing Companies: Third parties we utilize in our marketing or advertising campaigns, such as Google.

 

All such information sharing is subject to appropriate confidentiality and security obligations.

6. Data Retention

We retain personal information and other data only as long as necessary for the purposes outlined in this policy or as required by law. We have established internal retention policies and procedures for disposing of information that is no longer needed.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. This includes encryption, access controls, and regular security assessments.

No system can be guaranteed to be completely secure. Company does not guarantee that your information and data will never be exposed to unauthorized access, loss, or interception. You transmit your personal information and data to us at your own risk. Company will abide by applicable breach notification laws should a security breach occur.

8. Your Rights and Choices

Many state privacy laws require that consumers have a right to opt out of the use of their data in targeted advertisements. You may also request that we delete your personal information and data that you provide to us. You may opt out of the use of data in targeted advertising or require we delete your personal information and data by emailing us at legal@procircular.com.

9. Third-Party Links

Our Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

10. Children’s Privacy

The Site is not directed to individuals under the age of thirteen (or applicable age under local law), and we do not knowingly collect personal information from children.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective upon posting the revised Policy on the Site with an updated “Last Updated” date.

12. Contact Information

If you have questions or concerns about this Policy, please contact:

ProCircular, Inc.
Attn: Legal Department
legal@procircular.com