PROGRESS TRIBE INC. – PRIVACY & DATA GOVERNANCE POLICY

Last Updated: October 12, 2026

Effective Date: October 12, 2026

Your use of the Services is also governed by our Terms of Use, Medical Disclaimer, and Affiliate Disclosure.

Binding Notice & Agreement

This Privacy Policy describes Our policies and procedures on the collection, use, retention, sharing, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

By accessing, browsing, registering for, purchasing from, or otherwise interacting with our website (progresstribe.com), quizzes, mobile applications, newsletters, SMS programs, or digital features (collectively, the “Services”), you (“You” or “Your”) explicitly acknowledge that you have read, understood, and unconditionally agreed to all terms set forth in this Privacy Policy and our Terms of Use. If you do not agree, you must immediately discontinue use of the Services.

In this Privacy Policy, “Progress Tribe,” “Company,” “We,” “Us,” and “Our” refer to Progress Tribe Inc. and any current or future affiliates, subsidiaries, divisions, brands, or successors that operate the Services.

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Business, for the purpose of the CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Progress Tribe Inc.
  • Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
  • Consumer Health Data means information linked or reasonably linkable to a consumer that identifies past, present, or future physical or mental health status, including responses to the Menopause Weight Loss Roadblock Scorecard, reported symptoms, dietary preferences, and fitness habits.
  • Cookies are small files placed on Your computer or mobile device by a website, containing details of Your browsing history.
  • Data Controller, for the purposes of the GDPR and UK-GDPR, refers to Progress Tribe Inc.
  • Device means any device that can access the Service such as a computer, cellphone, or digital tablet.
  • Do Not Track (DNT) & Global Privacy Control (GPC) are mechanisms allowing internet users to control the tracking of their online activities across websites.
  • Facebook Fan Page is a public profile named Progress Tribe Facebook Fan Page specifically created by the Company on Facebook (https://www.facebook.com/ProgressTribe).
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Sale, for the purpose of the CCPA/CPRA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or communicating a Consumer’s personal information to a third party for monetary or other valuable consideration.
  • Service refers to the Website (progresstribe.com), our physical dietary supplements, digital memberships, and mobile applications.
  • Service Provider means any natural or legal person who processes data on behalf of the Company (Data Processors under GDPR).
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
  • You means the individual accessing or using the Service, or the company or legal entity on behalf of which such individual is accessing or using the Service.

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information, including:

  • Email address
  • First name and last name
  • Phone number and mobile device data (if you opt-in to SMS/text messaging or account features)
  • Address, State, Province, ZIP/Postal code, City
  • Payment and Financial Data: Processed securely via tokenization through our third-party payment processors (e.g., Stripe, PayPal). Raw credit card numbers are never stored on our servers.
  • Consumer Health & Lifestyle Data: Responses to the Menopause Weight Loss Roadblock Scorecard, reported menopause symptoms, dietary preferences, and fitness habits.
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service. It includes Your Device’s Internet Protocol address (IP address), browser type, browser version, pages of our Service that You visit, time and date of visit, time spent on pages, unique device identifiers (IDFA/AAID), and other diagnostic data.

Comments, User-Generated Content (UGC), Media, and Gravatar

  • Comments & Spam Detection: When visitors leave comments, reviews, or testimonials on the site, we collect the data shown in the form, the visitor’s IP address, and browser user agent string to help automated spam detection. Visitor comments may be checked through an automated spam detection service.
  • Gravatar Service Integration: An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it (Automattic Privacy Policy: https://automattic.com/privacy/). After approval of your comment, your profile picture is visible to the public in the context of your comment.
  • Media & EXIF GPS Data: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Tracking Technologies, Pixels, and Wiretap Consent

We use Cookies, web beacons, tags, scripts, and advanced tracking pixels (including Meta Conversions API and TikTok Pixel) to track activity on Our Service and store certain information.

  • Express Consent to Electronic Monitoring: By interacting with our forms, quizzes, and website inputs, you expressly consent to our collection, recording, and processing of your digital interactions, keystroke patterns, and browsing activities via cookies and tracking pixels for analytics, session monitoring, and conversion tracking.
  • Necessary / Essential Cookies (Session Cookies): Essential to provide You with services available through the Website, authenticate users, and prevent fraudulent use of accounts.
  • Cookies Policy / Notice Acceptance Cookies (Persistent Cookies): Identify if users have accepted the use of cookies on the Website (expires after 1 year).
  • Functionality Cookies (Persistent Cookies): Allow us to remember choices You make, such as login details, screen display choices, or language preferences. (Login cookies last 2 days; screen options cookies last 1 year; “Remember Me” persists for 2 weeks).
  • Tracking and Performance Cookies (Persistent Cookies): Used by third parties to track traffic, test new website features, and evaluate performance.

3. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service: Including fulfilling supplement orders, delivering digital memberships, and managing web infrastructure.
  • To manage Your Account: To manage Your registration and access to different functionalities available to registered users.
  • For the performance of a contract: Compliance and undertaking of purchase contracts for products, memberships, or services.
  • To contact You: By email, telephone calls, SMS text messages, or push notifications regarding updates, order fulfillment, security updates, and auto-renewal notices.
  • To provide marketing communications: News, special offers, targeted advertising, and custom audience creation (unless You opt out).
  • For Fraud Prevention & Security: To detect security incidents, protect against malicious or fraudulent activity, and handle chargeback disputes.
  • For Automated Decision-Making: To offer tailored supplement recommendations based on your Menopause Scorecard results.
  • STRICT AI / LLM TRAINING BAN: We explicitly do not and will not use your identifiable Personal Data, health quiz results, private communications, account details, or website content to train internal or third-party Artificial Intelligence (AI) algorithms, machine learning models, or Large Language Models (LLMs).

4. Disclosure, Sharing, and Marketing Data Processing

We may share Your personal information in the following situations:

  • With Service Providers & Marketing Platforms: To monitor and analyze the use of our Service, process payments, facilitate physical shipping and international customs clearance (e.g., USPS, FedEx, DHL), and manage customer communications through email service providers (e.g., Klaviyo).
  • With Advertising Partners & Retargeting Networks: To measure ad performance and deliver customized marketing campaigns and retargeting ads across advertising platforms (such as Meta, TikTok, Pinterest, and Google/YouTube Ads) via tracking pixels, conversions APIs, and custom audience tools. These marketing and advertising platforms act strictly as data processors on our behalf for campaign delivery and conversion tracking; they are contractually prohibited from using your identifiable Personal Data or quiz responses to train third-party AI models or machine learning algorithms.
  • For Business Transfers: In connection with any merger, sale of assets, financing, or acquisition, provided the acquiring entity strictly honors this exact Privacy Policy.
  • With Affiliates & Business Partners: To offer You certain products, services, or promotions, requiring them to honor this policy.
  • With other users: When You share personal information or interact in public community areas, such information may be viewed and publicly distributed by other users.
  • STRICT SMS RINGFENCING:Mobile information (including phone numbers and SMS opt-in consent data) will NEVER be shared with, sold to, rented to, or distributed to third parties, affiliates, or advertising partners for their own marketing or promotional purposes under any circumstances.
  • Law Enforcement & Legal Requirements: The Company may disclose Your Personal Data if required to do so by law, court order, or in response to valid requests by public authorities, or to protect the rights, property, and safety of the Company and the public.

5. Detailed Information on Third-Party Processing

6. Global Privacy Frameworks

1. Consumer Health Data & HIPAA Disclaimer (US States)

Progress Tribe Inc. is NOT a healthcare provider and is NOT a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). To the extent your Menopause Scorecard responses are classified as “Consumer Health Data” under the Washington My Health, My Data Act (MHMDA), Nevada SB 370, or similar state laws, we process this data strictly based on your affirmative, opt-in consent to provide personalized product recommendations. We never sell Consumer Health Data to data brokers.

2. GDPR (European Union) & UK-GDPR (United Kingdom)

If you are located in the EEA or the UK, Progress Tribe acts as the Data Controller.

  • Legal Basis: We process data based on Consent, Performance of a Contract, Legal Obligations, and Legitimate Interests.
  • Your Rights: Right to Request Access, Correction, Erasure, Data Portability, Object to processing, and Withdraw Consent.
  • Cross-Border Transfers: Data is processed in the US. We utilize Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) to ensure adequate legal protection.
  • Facebook Fan Page & Insights: The Company and Facebook act as Joint Controllers for our Fan Page (https://www.facebook.com/ProgressTribe). Facebook Privacy Policy: https://www.facebook.com/privacy/policy/.

3. Canadian Privacy Rights (PIPEDA & CASL)

For users in Canada, your data is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA). We strictly adhere to Canada’s Anti-Spam Legislation (CASL). We only send commercial electronic messages with express/implied consent, and all messages contain an instant unsubscribe mechanism.

4. Broad U.S. State Privacy Rights (VCDPA, CPA, CTDPA, TDPSA)

Depending on your state (including Virginia, Colorado, Connecticut, Utah, Texas), you have the right to Access, Delete, Correct, Opt-Out of targeted advertising, and the right to Appeal a denied data request by contacting us.

7. CCPA and CPRA Privacy (California Residents)

This section supplements our Privacy Policy and applies solely to California residents, fully updated for the California Privacy Rights Act (CPRA).

Categories of Personal Information Collected within the last 12 months:

  • Category A: Identifiers. (e.g., Name, email, IP address, account name). Collected: Yes.
  • Category B: California Customer Records. (e.g., Physical address, phone number, financial/credit card info). Collected: Yes.
  • Category C: Protected classification characteristics.Collected: No.
  • Category D: Commercial information. (e.g., Records of products purchased). Collected: Yes.
  • Category E: Biometric information. Collected: No.
  • Category F: Internet or network activity. (e.g., Website interactions, ad engagement). Collected: Yes.
  • Category G: Geolocation data. (e.g., Approximate physical location). Collected: Yes.
  • Category H: Sensory data.Collected: No.
  • Category I: Professional or employment-related information.Collected: No.
  • Category J: Non-public education information.Collected: No.
  • Category K: Inferences drawn from other personal information. (e.g., Preferences, health/lifestyle predispositions derived from quizzes). Collected: Yes.

Use, Disclosure, Sale, and Sharing

We use Categories A, B, D, F, G, and K for business purposes. While we do not sell data for money, sharing data with advertising partners for targeted advertising may constitute a “sale” or “share” under CCPA/CPRA. We may have shared Categories A, D, and F for these purposes.

Your Rights under CCPA/CPRA:

  • Right to Notice, Access/Request, Delete, Correct, and Limit Sensitive Personal Information (health/lifestyle data).
  • Right to Opt-Out (Do Not Sell/Share): You may direct Us not to sell or share Your personal information.
  • Right not to be Discriminated Against: We will not deny goods, charge different prices, or provide a lower quality of service for exercising your rights.

Do Not Sell My Personal Information & Global Privacy Control (GPC)

You have the right to opt out. Our website recognizes the Global Privacy Control (GPC) signal. You can also opt out via:

8. Retention and Security

  • Retention: E-commerce transaction records, shipping details, and financial histories are securely retained for up to seven (7) years to comply with tax, accounting, and anti-fraud legal obligations. Comments and comment metadata are retained indefinitely so we can recognize and approve follow-up comments automatically. Marketing and quiz data is retained until you opt out or request deletion. Once aggregated and fully de-identified, data is no longer considered personal data.
  • Security: We use commercially acceptable means (SSL/TLS encryption) to protect Your Personal Data. If a data breach occurs, we will notify you and relevant regulatory authorities as required by law.

9. Children’s Privacy & California Minors

The Service is intended strictly for adults 18 years of age and older. We do not knowingly collect personally identifiable information from anyone under the age of 18. If We become aware that We have collected data from a minor without verification of parental consent, We take steps to remove it immediately.

Under California Business and Professions Code Section 22581, California residents under 18 who are registered users may request removal of publicly posted content. Under California’s “Shine the Light” law, California residents can request information regarding the disclosure of personal data to third parties for direct marketing purposes.

10. Links to Other Websites and Embedded Content

  • External Links: Our Service may contain links to third-party websites not operated by Us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
  • Embedded Content from Other Websites: Articles on this site may include embedded content (e.g. videos, images, articles). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content.

11. Personal Liability Shield & Dispute Harmonization

  • Corporate Veil & Personal Liability Protection: You expressly agree that your sole legal recourse for any dispute, privacy grievance, or claim shall be directed exclusively against the corporate entity, Progress Tribe Inc. You hereby waive any right to pierce the corporate veil or to pursue, sue, or hold personally liable any individual founder, owner, officer, director, manager, employee, or agent of Progress Tribe Inc. in their individual, personal capacity.
  • Harmonization with Terms of Use: Any dispute, claim, or controversy arising out of or relating to this Privacy Policy or data privacy practices shall be resolved exclusively through the Mandatory Binding Arbitration, Class Action Waiver, Mass Arbitration Batching Protocol, and strict One-Year Statute of Limitations set forth in Section 35 of our Terms of Use.

12. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

13. Contact Us and Privacy Requests

If you have any questions about this Privacy Policy, wish to exercise your rights, or wish to contact our Data Protection Officer, You can contact us:

  • Legal Business Name: Progress Tribe Inc.
  • Email: he**@***********be.com or pr*****@***********be.com
  • Mailing Address: 12386 State Road 535, Suite 155, Orlando, FL 32836
  • Website Contact Page: https://progresstribe.com/contact

Note on Request Verification & Fees: To protect your data, we may require verification of your identity before fulfilling access or deletion requests. If a request is manifestly unfounded, excessive, or repetitive, we reserve the right to charge a reasonable administrative fee or decline the request to the extent permitted by applicable law.