Privacy Policy

Last Updated: March 3, 2026

PROKEEP ONLINE PRIVACY NOTICE

Prokeep takes your privacy very seriously. We understand that protecting the privacy and confidentiality of your personal information is of the utmost importance. Our commitment to protect your personal information will continue under the principles and guidelines described below.

This Online Privacy Notice (this “Notice”) describes how we collect, use and disclose your information and how to exercise any rights you might have with respect to such information. This Notice governs information we collect by and through any of our online interfaces to which a copy of this Notice is posted, including, without limitation, https://www.prokeep.com/ and its subdomains; applications we have placed on third-party sites; social media presences; digital advertising campaigns; and mobile applications we make publicly available (each, a “Site” and, collectively, the “Sites”); information we collect from you or third parties through a Site; or through any other means in connection with our services, products or other business activities, including, without limitation, any information that you may voluntarily provide such as when you contact us via phone, email or webform (collectively, the “Services”).

For purposes of this Notice, (i) the terms “we,” “us,” “our” and “Prokeep” refer to Prokeep Inc. and its present and future subsidiaries and affiliates; and (ii) the terms “you,” “your” and “yours” refer to any natural person who accesses or uses a Site or the Services for business or professional purposes.

Please read this Notice carefully as it contains important information about our practices and forms part of our Online Terms of Use. By using or accessing any Site or Services, you confirm your agreement to the terms and conditions of this Notice as may be in effect at that time and consent to the processing of your personal information as set forth in this Notice. If you do not agree with this Notice or the Online Terms of Use, you must refrain from using our Sites and Services.

This Notice should be read in conjunction with other documents that we provide to you. This documentation may include sections relating to the use and disclosure of information. Where a conflict exists between the terms of this Notice and any other document related to data privacy, security, use or protection, the terms of this Notice will apply. The policies described in this Notice continue to apply even if your relationship with us ends.

• KEY TERMS
• TYPES OF PERSONAL INFORMATION COLLECTED AND HOW WE COLLECT IT
• USE OF PERSONAL INFORMATION
• OPT-IN DATA USES AND CONSENT FRAMEWORK
• HOW PERSONAL INFORMATION IS DISCLOSED
• COMMUNICATIONS
• COOKIES AND TRACKING TECHNOLOGIES
• THIRD PARTY WEBSITES AND LINKS
• OPT OUT INFORMATION
• CHILDREN’S INFORMATION
• SECURING YOUR INFORMATION; RISKS OF PERSONAL INFORMATION DISCLOSURE
• DATA RETENTION
• INTERNATIONAL USERS: INTERNATIONAL TRANSFER OF INFORMATION COLLECTED
• PROTECTION OF YOUR PERSONAL INFORMATION
• PRIVACY RIGHTS
• ACCESSIBILITY
• LIMITATION OF LIABILITY
• COMPLAINTS
• UPDATES AND CHANGES TO THIS NOTICE
• HOW TO CONTACT US

The following key terms utilized in this Notice have the meanings set out below. Key terms have the same meaning regardless of whether they appear in singular or in plural.

Depending on the nature of your interactions with us, including when you visit our Sites or use our Services, we may collect the following information:

• Personal information, which may include:
  • First and last name
  • Alias
  • Phone number
  • Physical address (including billing, service and mailing address)
  • Email address
  • Fax number
  • Demographic information (including gender, age, date of birth, education, marital status, and employer information)
  • Billing information (such as names and types of accounts, payment information, and the area in which you receive Services), bank account information and payment and credit card information
  • Tax ID number, social security number, driver’s license number and other government card information (when legally required)
  • Account numbers
  • Usernames, passwords, logins and other identification information
  • Account, communication and opt-out preferences and other details
  • Other non-public information
• Commercial information such as the type(s) of Services, purchase information, Order Data, transaction data, customer type, contract terms and other related information;
• Information from cookies, pixel tags and other technologies to collect information and learn from your visit or use of the Sites and Services;
• Your Internet Protocol (“IP”) address, any referring URL and other unique device identifiers;
• Configuration information about the device you are using, including, but not limited to, your device type, web browser type (e.g., Google Chrome, Microsoft Edge) and version, operating system type and version, display/screen settings, language preferences and other browser-related information;
• Settings from your mobile device, such as location, diagnostics and performance, including geolocation and other location information transmitted by your device, if you have enabled location services on such device;
• Website analytics information, such as pages visited, search terms used and average time spent on a particular page;
• Search engine traffic referral information; and
• Responses to advertisements and promotions.

We may also collect this information in other circumstances from you online or offline, including directly from you when you provide it to us and from third-party data sources. You are not required to provide your personal information; however, if you choose not to provide such information, you may not be able to use some or all of the features of our Sites or Services and we may not be able to fulfill your request.

We (and our third-party service providers) may use the information we collect for various purposes, including:

• To provide, maintain and improve our Services (including to establish, maintain or close an account and to make determinations about the circumstances of any such account);
• For Business Purposes, including data analysis; audits; developing, evaluating, analyzing, enhancing and improving content, features, Sites and Services; billing, credit risk reduction and collection activities; accounting; determining usage and identifying usage trends; performing market research; and determining the effectiveness of promotional campaigns;
• To provide you with non-personalized and targeted advertising and marketing emails, surveys and other promotional materials or company information that we believe of interest to you (unless you have opted not to receive such information);
• To personalize your experience on a Site;
• To help you find and connect with people and businesses that may be beneficial to you;
• To contact you and to inform you about important information regarding, and to administer, the Sites or Services; changes to terms, conditions and policies; and for other administrative purposes, including mobile application push notifications;
• To allow you to participate in interactive features of our Sites when you choose to do so;
• To process, evaluate and respond to account and service inquiries, requests and applications;
• To detect, prevent, diagnose and otherwise address technical and security issues;
• To protect against and prevent fraud, unauthorized activity, claims and other liabilities;
• To conduct other day-to-day operations, such as to disclose information as outlined below under the section “How Personal Information is Disclosed,” to evaluate and improve our business and to perform compliance and training activities;
• To comply with laws, regulations and industry standards, and to comply with any other legal process, regulatory or law enforcement requirements;
• To allow you to utilize features within our Sites by granting us access to information from your device;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Users is among the assets transferred; and
• For other purposes about which we notify you.
• Product Development: Improving Services features and functionality based on usage patterns and user needs;
• Order Automation Enhancement: Training machine learning models to improve order processing accuracy, efficiency and automation capabilities;
• Platform Analytics: Analyzing platform-wide trends to enhance user experience and develop new features that benefit all users; and
• Messaging Effectiveness Analysis: Generating insights regarding the effectiveness of outbound messaging activities to help optimize communication strategies.
• Data from at least five (5) separate distributors is available for aggregation; and
• No single distributor contributes more than twenty-five percent (25%) of the underlying data in any benchmark or metric.
• Opt-In: You may choose to opt into Tier 1, Tier 2, both, or neither. Each tier requires separate consent;
• Change Anytime: You may change your consent preferences at any time through your account settings or by contacting us at legalnotices@prokeep.com;
• No Service Impact: Your access to and use of the Prokeep Services is not conditioned on providing consent for either Tier 1 or Tier 2 data uses. You may decline or withdraw consent without affecting your service; and
• Effect of Withdrawal: If you withdraw consent, we will stop using your Order Data for the applicable tier prospectively. Previously aggregated Benchmarking Data (which does not identify you) may continue to be used as part of historical benchmarks.
• With our subsidiaries or affiliates;
• With organizations with which we partner to offer Services;
• With other parties to whom you have authorized or directed us to disclose your information and where otherwise necessary to comply with our contractual obligations or with your instructions;
• With government entities, authorities and other third parties as needed for legal, regulatory or similar purposes, such as to respond to a warrant, subpoena, court order, governmental audit or investigation, law enforcement request, legal order or other legal process; to exercise or defend legal claims or otherwise in connection with any litigation or dispute; if we determine (in our sole discretion) that disclosure is reasonably necessary to protect against fraud, tax evasion and financial crime; to protect the property or other rights of us or other users, third parties or the public at large; or to stop any illegal, unethical or legally actionable activity;
• With service providers and other third parties that provide various services to us or to otherwise support our internal ancillary processes, such as those we use to help detect and prevent fraud, support our system and security, process payments, collect outstanding fees and other amounts, improve our online services and to better market and advertise our services to you;
• With your explicit consent under our Tier 2 opt-in framework, we may disclose Benchmarking Data with other distributors who use our Services; and
• To a buyer or other successor in the event of a merger, acquisition, divestiture, bankruptcy, restructuring, reorganization, dissolution, or other sale, transfer or disposition of some or all of our assets or equity interests.

Other than to a buyer or successor of our business, Prokeep does not lease or Sell your personal information to any third party.

We may use information that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.

We do not intentionally solicit or require SPI from you. While we strive to avoid the processing of SPI, Prokeep is not responsible for any SPI you may voluntarily disclose in user-generated content or communications.

Prokeep provides you with choices regarding how we use your Order Data and related information. We have established a two-tier consent framework that gives you control over how your data contributes to broader platform improvements and industry insights.

Tier 1: Standard Data Uses

With your consent, Prokeep may use your Order Data and related information for the following Strategic Uses:

These Strategic Uses benefit the Prokeep platform and its users collectively by enabling continuous improvement of our Services. Your Order Data used for these purposes will not directly identify you or your customers to other Prokeep users.

Tier 2: Benchmarking and Comparative Analytics

With your separate and explicit consent, Prokeep may use your Order Data to create Benchmarking Data. Benchmarking Data allows us to provide industry insights and comparative analytics that help distributors understand their performance relative to industry trends.

Aggregation Standards

To protect your privacy and maintain confidentiality, Benchmarking Data is created only when:

These standards ensure that Benchmarking Data does not contain any information that could directly or indirectly identify individual distributors, their specific customers, or any Personal Information.

Managing Your Consent Preferences

You have full control over your consent preferences for both Tier 1 and Tier 2 data uses:

For questions about your consent preferences or how your data is used, please contact us at legalnotices@prokeep.com.

In addition to the uses mentioned or described elsewhere in this Notice, from time to time, we may disclose personal information as permitted or required by law or regulation or for any other purpose described in this Notice or the Online Terms of Use. More specifically, we may disclose Personal Information:

It is our policy to only use third-party service providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with appliable legal requirements for transferring personal information outside of the jurisdiction in which it was originally collected.

To the extent that personal information has been deidentified, aggregated or otherwise rendered anonymous in such a way that you and your device are no longer reasonably identifiable, such information will be treated as non-personal information and the terms of this Notice will not apply.

User-Generated Content: Communications

Prokeep centralizes communication by providing a shared workspace that streamlines communication channels in one platform. To facilitate our centralized communication features, we may collect, store, and analyze the User-generated content you create. This may include visual, audio, and electronic communications uploaded or generated by you (e.g., text messages, fax, text or audio or video web chats, emails, and digital images sent through the Application).

The collection and analyzation of your communications helps us operate and develop our Services, monitor and secure our Services, identify Service usage trends, and better address your needs regarding the Services.

Communications Between You and Prokeep

The communications between you and Prokeep may take place via electronic means, whether you visit the Services or send us emails, or whether we post notices on the Services or communicate with you via email, telephone call, text message, or mobile push notifications (collectively the “Communications”).

When engaging in the Services (e.g., creating an account; logging-in to the Application, making a privacy request), you may be asked to provide an email address and mobile phone number. The collection of your email address and mobile phone number allows you to receive direct Communications from us. Communications from or on behalf of us may include but are not limited to the use of the Services, User support, and informational communications concerning the Services. We also have a Business Interest in using your Personal Information for marketing to you; we offer our Users the opportunity to sign up via email to receive news about new offers and special promotions offered by us.

As a User, you have the right to opt out of receiving Communications at any time. If you would like to discontinue receiving email Communications, you may opt out by using the “Unsubscribe” link found in our emails, replying “STOP” to our text messages, turning off notifications from our Application, or disabling push notifications through your mobile device's settings.

We may ask you to confirm or update your preferences if you ask us to provide more services in the future, or if there are changes in the law, regulation, or the structure of Prokeep as a business.

We, our service providers and other organizations we work with may deploy and use various tracking technologies to collect information, including:

Cookies

“Cookies” are small text files that can be placed on your system when you visit a website. Cookies allow us to collect information such as browser type, time spent on a website, pages visited, language preferences and information about your relationships with us. Cookies allow us to facilitate image changes, display information more effectively, collect website traffic and personalize and customize your online experience and our Services to your needs. Our Sites do not require users to accept cookies, and you can set your browser to notify you when you receive a cookie, giving you the opportunity to decide whether to accept it. If you choose not to accept cookies, you may experience some reduction in graphics and other personalized Services. You also may need to accept cookies to maintain certain online advertising opt-out elections.

Pixel Tags and Similar Technologies

“Pixel tags” (also known as “web beacons” or “clear GIFs”) are small graphic images (usually invisible) that can be embedded in content and ads on a Site page and HTML-formatted email messages that may, among other things, track the actions of users and email recipients, measure the effectiveness of communication and compile statistics about Site usage and response rates. These web beacons may then be used to recognize our cookies and to monitor certain user interactions with our Sites.

Location Tracking on Mobile Devices

Certain applications on mobile devices may transmit information to us about your location. We may use that information to improve the Sites and Services we provide to you as well as improving our services in your area.

“Do Not Track” Signals

Your browser may offer you a “Do Not Track” option or similar setting, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Our Sites do not currently respond to such requests or settings. If you make such a request or enable such a setting, it will not prevent the collection of information about your online activities over time and across third-party websites when you visit our Sites.

Use of Cookies and Tracking Technologies

Information collected through tracking technologies is used for many purposes, including, for example, to:

• Provide useful features to simplify your experience when you use or return to our Sites and Services;
• Deliver relevant content based on your preferences, usage patterns and location;
• Monitor and evaluate the use and operation of our Sites and Services;
• Analyze traffic regarding our Sites and Services and on websites or mobile applications of third parties;
• Customizing and improving our Sites and Services; and
• Enabling and supporting security features on our Sites and Services.

The information and disclosures contained in this Notice apply only to our Sites. Our Sites may contain links to other third-party websites that are not operated by us for your convenience and information, including various social media websites. We do not own, operate, or control such third-party websites or the content therein, and we have not reviewed, and cannot review, all of the material, including goods or services, made available through third-party websites. We do not guarantee, and are not responsible for, the privacy, security, practices or content of such third-party websites, including the accuracy, completeness or reliability of their information.

Any link to or from another website is for the convenient use of visitors only and does not constitute an affiliation, sponsorship, representation, warranty or endorsement of the owner of the linked website or of any third-party content, products or services. If you click a third-party link, you will be directed to that third party’s website. We accept no responsibility for the content, products or services found on any third-party website linked to or from a Site or for any loss of damage that may arise from your use of them. Notwithstanding anything to the contrary contained in this Notice, we reserve the right to prohibit linking to a Site for any reason in our sole and absolute discretion.

We strongly encourage you to read the terms of use and online privacy statements for any other third-party services or third-party website before permitting them to collect or use your personal information. If you decide to access any of the third-party websites linked, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

If you do not want us to use your personal information for certain marketing purposes, you may take advantage of applicable opt-out options such adjusting your user preferences in your account profile, opting out of promotional emails through an unsubscribe link or by contacting us directly at legalnotices@prokeep.com. Despite your indicated email preferences, we may still send you administrative emails regarding our Services, including, for example, administrative confirmations and notices of updates to this Notice.

COPPA

The Children's Online Privacy Protection Act (“COPPA”) protects the online privacy and personal information of children under thirteen (13) years of age. Children under the age of thirteen (13) are not permitted to use our Sites and we do not intentionally or knowingly collect or maintain personal information from anyone under the age of thirteen (13). If you are under the age of thirteen (13), do not use, or provide any information on, our Sites. If we obtain actual knowledge that a user is under the age of thirteen (13) without verified parental consent, we will delete that user’s personal information. If you believe we might have any information from or about a child under the age of thirteen (13), please contact us using the contact information below.

We recommend that children between the ages of thirteen (13) and eighteen (18) obtain their parents’ permission before submitting information to us over the Internet. By using our Sites, you are representing that you are at least eighteen (18) years old.

Quebec Private Sector Act: Minor’s Eligibility

For residents of the province of Quebec, general browsing of our Services is not intended for users under the age of fourteen (14). We do not intentionally or knowingly collect or maintain information from children under fourteen (14) who are residing in Quebec and we specifically prohibit such children from entering any parts of the Services where Personal Information may be collected.

If you are a resident of Quebec under the age of fourteen (14), do not use, or provide any information on, our Sites. If we obtain actual knowledge that a resident of Quebec is under the age of fourteen (14) without verified parental consent, we will delete that user’s personal information. If you believe we might have any information from or about a child who is a resident of Quebec under the age of fourteen (14), please contact us using the contact information below.

Privacy Rights for California Minors in the Digital World Act

If you are a California resident under the age of eighteen (18) and are a User of our Services, you may request that we remove the Personal Information you have posted on our Services. Please contact us using the contact information below so we may delete the information collected. Keep in mind, however, that certain California or federal laws may stop us from deleting specific categories of your Personal Information, if applicable.

Prokeep is very concerned about safeguarding the confidentiality of Personal Information. We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Information.

However, due to the inherent nature of the Internet as an open global communications vehicle, we make no guarantee as to the security of your information or that your information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. BY USING OUR SERVICES OR BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.

Prokeep will notify you in accordance with applicable laws in the event of a security breach relating to your Personal Information.

Personal information we collect from you may be kept for as long as it is required or necessary for the purposes set out in this Notice. Without limiting the generality of the foregoing, we may retain and use your personal information to the extent necessary for our legitimate business purposes, to comply with our legal or regulatory obligations (for example, if we are required to retain your data to comply with applicable laws), to resolve disputes, to perform contractual obligations and to enforce our legal agreements and policies. We may also be allowed to retain your personal information for a longer period if you have given consent to such processing, as long as such consent is not withdrawn.

If you are a User located outside of North America, please be aware that Personal Information may be transferred, stored, and processed outside of your country, including in the USA and Canada. Although we take steps to provide adequate safeguards, the data protection laws in these countries might not be as comprehensive as those in your country. By submitting Personal Information to us, you understand that your Personal Information may be subject to the laws of applicable jurisdictions.

We endeavor to protect the privacy and security of Personal Information wherever it is transferred, and to use it consistent with your relationship with us and the practices described in this Notice.

Prokeep takes precautions to protect the confidentiality, security and integrity of the information that we collect and process by applying physical, technical, administrative and operational safeguards designed to protect such information against unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction, alteration or accidental loss. Access to such information is limited, and policies and procedures are in place that are designed to safeguard such information.

Even with safeguards in place, however, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, hile we strive to protect information transmitted on or through our Sites or Services, we cannot ensure or warrant the security of any information you transmit to us, and you provide such information at your own risk.

We also encourage you to protect any usernames, passwords or other credentials you use to access our Sites and to use a password that you do not use on any other website or with any other online services. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you must keep this password confidential. We ask that you not disclose your password with anyone and urge you to be careful about giving out information in any public areas of the Sites. The information you disclose in public areas may be viewed by any user of the Sites.

You may be able to exercise certain consumer rights depending on your jurisdiction. Such consumer rights may include the following:

• Right to Know/Access: The consumer right to obtain confirmation of whether your personal information is being processed by us, the categories of such personal information being processed and, where applicable and permissible, access to such personal information.
• Right to Correct: The consumer's right to update, rectify and correct your inaccurate personal information maintained by us.
• Right to Delete: The consumer's right to have personal information maintained by us erased or otherwise deleted.
• Right to Limit Processing of SPI: The consumer right to restrict, limit or opt-out from our processing of SPI.
• Right to Object to Automated Decision-making or Profiling: The consumer right to not be subject to automated decision-making if such a decision is based solely on automated processing and produces legal effects concerning you or similarly significantly affects you.
• Right to Data Portability: The consumer right to (i) obtain personal information maintained by us in a commonly used, machine-readable format, and (ii) where technically feasible and required by applicable privacy laws, request that such personal information be transferred to a different entity.
• Right to Opt-out of Sale or Sharing of Personal Information: The consumer right to direct us to not Sell your personal information or Share your personal information for cross-contextual behavioral advertising.

Quebec Residents: You have the right to request cessation of dissemination of your Personal Information (de-indexing) where the dissemination contravenes law, the information is outdated or incomplete, or dissemination may cause serious harm to your reputation or privacy.

Canadian Residents: Where we process your Personal Information based on consent, you may withdraw that consent at any time, subject to legal or contractual restrictions. Canadian residents may file privacy complaints with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca, 1-800-282-1376) or applicable provincial privacy commissioners.

To exercise any consumer rights you may have, you can contact us as set forth in this Notice. Please note that there may be limitations in the scope and frequency of the foregoing requests under applicable privacy laws. You may also have the right to appeal a decision made by us in respect of your consumer rights request.

If you would like to receive this Notice in a different format (e.g., audio; large print), please contact us via the contact information below.

We operate and maintain our Services for the convenience of visitors and Users and are committed to abiding by the terms of this Notice. However, we do not warrant against breaches of this Notice and make no promises to you, express or implied, by posting this Notice.

If you are concerned about an alleged breach of privacy law or other regulation, please contact us via the contact information below. We will investigate the matter and provide information about how it will be handled and resolved.

Prokeep reserves the right to change, modify, update or otherwise amend this Notice at any time and from time to time.

In the event of any modification, we will let you know via email or a prominent notice on our Sites or Services prior to the change becoming effective and update the “last updated” date at the top of this Notice.

We therefore encourage you to refer to this Notice periodically to ensure that you are informed of changes. Unless otherwise stated, changes to this Notice are effective immediately upon posting. By continuing to use the Sites or Services following such changes, you are agreeing to the terms of the revised Notice.

If you have any questions or concerns about this Notice or our privacy practices generally or to make a consumer request regarding your personal information, please contact us via email at legalnotices@prokeep.com.