Privacy Policy

This Privacy Policy (the “Policy”) describes how VSABF, LLC, doing business as CliniPeptide (“CliniPeptide,” “we,” “us,” or “our”), collects, uses, discloses, retains, and otherwise processes information in connection with our website located at www.clinipeptide.com (the “Site”) and the related inquiry, ordering, verification, and account services we make available to our customers and prospective customers (collectively, the “Services”).

CliniPeptide is a research-grade peptide supplier. All products are supplied For Research Use Only — Not for human use or consumption, and are intended solely for qualified researchers, physicians, laboratories, and institutions engaged in laboratory and scientific research. Our Services are directed to professional and institutional users on a business-to-business basis and are not intended for, or directed to, consumers or the general public. This Policy should be read together with our Terms of Service and any other notices we provide at the point of collection.

1. Scope of This Policy and Data Controller

This Policy applies to information we collect through the Site and the Services, through written, telephonic, and electronic correspondence with us, and through our customer-relationship and business systems. It does not apply to information collected by third parties whose websites, platforms, or services may be linked to or referenced from the Site, each of which is governed by its own privacy practices.

For purposes of this Policy, the entity responsible for determining the purposes and means of processing your information — the data controller (or “business” under applicable United States privacy law) — is:

• VSABF, LLC dba CliniPeptide
• 3440 Hollywood Blvd, Suite 415, Hollywood, FL 33021
• (954) 715-1089
• www.clinipeptide.com

Capitalized terms used in this Policy have the meanings given to them where defined. References to “personal information” mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, and include “personal data” as that term is used under applicable data-protection law.

2. Categories of Information We Collect

The categories of information we collect depend on how you interact with us and the Services. Because our Services are directed to professional and institutional users, much of the information we collect relates to you in your professional capacity and to the organization on whose behalf you act.

2.1 Inquiry, Contact, and Professional Information

When you submit an inquiry, request information, seek to establish an account, place or discuss an order, or otherwise correspond with us, we collect the information you provide, which may include:

• your name, professional title, and role;
• your business or institutional affiliation, department, and the nature of your research activities;
• business contact details, including email address, telephone number, and shipping and billing addresses;
• professional identifiers and credentials used to verify research and professional eligibility, which may include a National Provider Identifier (NPI), a Drug Enforcement Administration (DEA) registration number, state or institutional license or registration numbers, institutional or laboratory affiliation, and comparable professional or research credentials;
• order, transaction, and account information, including products requested, quantities, lot and certificate-of-analysis (COA) references, correspondence history, and records of verification; and
• any other information you choose to provide in the body of an inquiry, message, or attachment.

We do not request, and you should not provide, information concerning the diagnosis, treatment, or care of any individual, or any other special-category or sensitive personal information that is not necessary for the professional and research purposes described in this Policy.

2.2 Information Collected Automatically

When you access or use the Site, we and our service providers automatically collect certain technical and usage information through cookies and similar technologies, which may include:

• Internet Protocol (IP) address and approximate location derived from it;
• device, browser, and operating-system characteristics, language settings, and screen attributes;
• pages and resources viewed, referring and exit pages, links and features used, and the dates, times, and duration of activity; and
• diagnostic, performance, and security-event data generated by your interaction with the Site.

2.3 Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar technologies to operate and secure the Site, remember your preferences, and understand how the Site is used. These technologies are described further in Section 7 (Cookies, Analytics, and Your Choices).

3. Sources of Information

We collect information from the following categories of sources:

• Directly from you, when you submit an inquiry, correspond with us, request or place an order, undergo eligibility verification, or otherwise interact with the Services;
• Automatically, through cookies and similar technologies when you use the Site, as described in Sections 2.2 and 2.3;
• From the organization you represent, where a colleague, administrator, or authorized representative provides information in connection with an account or order; and
• From third-party service providers and verification sources, such as analytics, fraud-prevention, and credential- or registry-verification providers, that help us confirm professional eligibility and protect the integrity of the Services.

4. Purposes of Processing and Legal Bases

We process information for the purposes set out below. Where the General Data Protection Regulation (“GDPR”) or comparable data-protection law applies, we rely on the legal bases indicated.

• To respond to your inquiries and communicate with you regarding the Services, products, specifications, and your correspondence. Legal bases: performance of, or steps taken at your request prior to entering into, a contract; and our legitimate interests in responding to professional inquiries.
• To verify professional and research eligibility, including confirming that you are a qualified researcher, physician, laboratory, or institution and that products supplied For Research Use Only are appropriate to your professional capacity. Legal bases: compliance with legal obligations; performance of a contract; and our legitimate interests in supplying products responsibly and only to qualified recipients.
• To process, fulfill, and administer orders, including arranging shipment and providing lot-specific COA, identity (ESI-MS), purity (HPLC), and specification documentation. Legal bases: performance of a contract; and our legitimate interests in operating our business.
• To operate, maintain, and improve our customer-relationship management (CRM) and business systems, conduct internal record-keeping, and analyze and improve the Site and the Services. Legal bases: our legitimate interests in administering and improving our business; and, where required, your consent.
• To secure the Site and prevent fraud and misuse, including detecting, investigating, and responding to security incidents, unauthorized access, and prohibited or unsafe use. Legal bases: our legitimate interests in protecting the Site, our customers, and our business; and compliance with legal obligations.
• To comply with law and to establish, exercise, or defend legal claims, including responding to lawful requests, maintaining required records, and enforcing our Terms of Service. Legal bases: compliance with legal obligations; and our legitimate interests in protecting our rights.

Where we rely on legitimate interests, we have assessed that those interests are not overridden by your interests or fundamental rights. Where we rely on your consent, you may withdraw it at any time as described in Section 11, without affecting the lawfulness of processing carried out before withdrawal.

5. How We Use Information

Consistent with the purposes and legal bases above, we use the information we collect to: respond to and manage professional inquiries and correspondence; verify eligibility and maintain verification records; process and fulfill orders and provide associated technical documentation; administer accounts and our CRM and business systems; personalize and improve the Site and the Services; monitor, secure, and protect the integrity of our systems; satisfy our legal, regulatory, accounting, and record-keeping obligations; and exercise or defend legal rights. We do not use the information we collect to make therapeutic, clinical, diagnostic, or human-use claims, and our communications address our products solely as research compounds in a laboratory and scientific context.

6. How We Disclose Information

We disclose information only as described in this Policy. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. We may disclose information in the following circumstances:

• Service providers and processors. We engage third parties to perform functions on our behalf — including website hosting and infrastructure, analytics, communications and email delivery, CRM and order-management, shipping and logistics, payment processing, credential and identity verification, and security and fraud-prevention — and disclose information to them as needed to provide those services. These parties are bound by contractual obligations to process information only on our documented instructions, to keep it confidential, and to safeguard it.
• Professional advisors. We may disclose information to our attorneys, auditors, accountants, insurers, and other professional advisors where reasonably necessary in the course of the professional services they render to us.
• Legal, regulatory, and safety. We may disclose information where we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or a governmental or regulatory request; to enforce our Terms of Service and other agreements; or to protect the rights, property, safety, or integrity of CliniPeptide, our customers, or others, including for fraud prevention and to address actual or suspected unsafe or prohibited use.
• Business transfers. In connection with, or during negotiations of, any merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or other corporate transaction, information may be disclosed to, or transferred to, a successor or affiliated entity as part of that transaction, subject to appropriate confidentiality protections.
• With your direction or consent. We may disclose information for any other purpose disclosed to you at the time of collection or to which you otherwise consent.

7. Cookies, Analytics, and Your Choices

The Site uses cookies and similar technologies that are strictly necessary to operate the Site and provide core functionality, as well as preference, performance, and analytics technologies that help us understand and improve how the Site is used. We use analytics providers to compile aggregated and de-identified statistics about Site activity. These providers may collect technical and usage information as described in Section 2.2 and process it on our behalf.

You can control cookies through your browser settings, which typically allow you to block or delete cookies and to receive a warning before a cookie is stored. Disabling certain cookies may affect the availability or functionality of parts of the Site. Where required by applicable law, we obtain consent for non-essential cookies through the mechanism presented on the Site, and you may adjust your preferences at any time using that mechanism.

8. Do-Not-Track

Some browsers offer a “Do-Not-Track” (DNT) signal. Because there is not yet a common industry or legal standard for recognizing and responding to DNT signals, the Site does not currently respond to them. We will continue to monitor developments and update our practices if a recognized standard is adopted. Separately, where applicable law treats a recognized opt-out preference signal (such as the Global Privacy Control) as a valid request to opt out of certain disclosures, we honor such signals to the extent required.

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, disclosure, loss, or destruction. These measures include access controls, encryption of data in transit, network and application security controls, and policies governing the handling of information by our personnel and service providers. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any credentials used to access the Services and for promptly notifying us of any suspected unauthorized use.

10. Data Retention

We retain information for as long as necessary to fulfill the purposes for which it was collected, including to provide and administer the Services, to maintain eligibility-verification and transaction records, to operate our CRM and business systems, and to satisfy our legal, regulatory, accounting, tax, and record-keeping obligations and to resolve disputes and enforce our agreements. When information is no longer required for these purposes, we will delete, de-identify, or anonymize it, or securely isolate it from further processing. The criteria we use to determine retention periods include the nature and sensitivity of the information, the purposes for which it is processed, applicable legal and regulatory requirements, and the existence of any actual or anticipated legal claim.

11. Your Privacy Rights

Depending on your jurisdiction and subject to applicable conditions and exceptions, you may have certain rights regarding your personal information.

11.1 Rights Under United States State Privacy Laws (CCPA/CPRA and Similar)

If you are a resident of California or another U.S. state with a comprehensive consumer-privacy law, you may have the right to:

• request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties to which we disclose it;
• request that we correct inaccurate personal information we maintain about you;
• request that we delete personal information we have collected from you, subject to legal exceptions;
• opt out of the “sale” or “sharing” of personal information and the use of sensitive personal information for certain purposes — noting that, as stated in Section 6, we do not sell or share personal information; and
• not receive discriminatory treatment for exercising any of these rights.

11.2 Rights Under the GDPR and Similar Laws

If you are located in a jurisdiction governed by the GDPR or a comparable data-protection law, you may have the right to access; to rectification; to erasure; to restrict or object to processing; to data portability; and, where processing is based on consent, to withdraw that consent at any time. You also have the right to lodge a complaint with your competent supervisory authority.

11.3 How to Exercise Your Rights

To exercise any of these rights, please contact us using the details in Section 14. We will verify your request, which may require confirming information we hold about you, before responding. You may use an authorized agent to submit a request where permitted by law; we may require verification of the agent’s authority. We will respond within the timeframes required by applicable law. Certain information may be exempt from these rights, and we may decline a request where an exception applies, in which case we will explain our basis for doing so.

12. International Transfers

We are located in the United States, and the information we process may be stored and processed in the United States and in other jurisdictions where we or our service providers operate. These jurisdictions may have data-protection laws that differ from those of your jurisdiction. Where we transfer personal data from a jurisdiction that restricts cross-border transfers, we implement appropriate safeguards required by applicable law — such as standard contractual clauses or another recognized transfer mechanism — to protect that information.

13. Intended Audience; No Minors

The Site and the Services are intended solely for professional and institutional users acting in their professional capacity, and are directed to individuals who are at least twenty-one (21) years of age. The Services are not directed to, or intended for use by, minors, and we do not knowingly collect personal information from any individual under twenty-one (21) years of age or from any individual who is not acting in a professional or institutional research capacity. If we learn that we have collected information from such an individual in a manner inconsistent with this Policy, we will take reasonable steps to delete it.

14. Contact Us; Privacy Inquiries

If you have questions about this Policy, wish to exercise your privacy rights, or have a concern about how we handle your information, please contact us:

• VSABF, LLC dba CliniPeptide — Privacy Office
• 3440 Hollywood Blvd, Suite 415, Hollywood, FL 33021
• (954) 715-1089
• www.clinipeptide.com

For privacy-specific and data-protection matters, please direct your correspondence to the attention of our Privacy Office at the address above. We will route your inquiry to the individual responsible for overseeing our privacy practices and respond as required by applicable law.

15. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, the Services, or applicable law. When we make changes, we will revise the “Last updated” date above and, where required by law or where the changes are material, provide additional notice. Your continued use of the Site or the Services after the effective date of a revised Policy constitutes your acknowledgment of the updated terms. We encourage you to review this Policy periodically.