Effective Date: January 1, 2026 · Last Updated: June 1, 2026
Entity: PAG Pharmatech America LLC (Springville, Utah, USA)
Scope: Global Contract Development & Manufacturing Organization (CDMO) Operations
1. Executive Summary & Scope
PAG Pharmatech America LLC ("PAG," "we," "our," or "us") operates an FDA-registered, cGMP-certified dietary supplement CDMO facility headquartered in Springville, Utah. As a commercial manufacturing partner serving global brand owners, DTC supplement companies, and institutional distributors across North America, Europe, and Asia-Pacific, we treat corporate privacy, proprietary formulation data, and personal information with enterprise-grade security.
This Privacy Policy outlines our transparent standards for collecting, managing, processing, and safeguarding technical and commercial information provided to us through digital communications, RFQ (Request for Quote) submissions, contract negotiations, and website interactions.
B2B Formulation Confidentiality & NDA Alignment
We recognize that proprietary ingredient blends, custom delivery specifications, target bill of materials (BOM), and trade secrets represent critical intellectual property (IP). All formulation technical transfers, lab sample requests, and contract manufacturing discussions are strictly protected under mutual Non-Disclosure Agreements (NDAs) enforced by our legal and regulatory affairs departments.
2. Categories of Information We Collect
To evaluate manufacturing feasibility, generate commercial quotes, perform batch record logging, and maintain regulatory compliance, we collect data across several operational categories:
A. Commercial & Inquiry Data
When procurement officers, R&D directors, or brand founders contact our team, we collect business contact details required to process commercial engagements, including:
- Full Name, Corporate Job Title, and Department.
- Company Name, Registered Address, and Primary Operating Jurisdiction.
- Business Email Address and Direct Contact Phone Number.
- Project Parameters: Desired dosage form (gummies, powders, tablets, softgels, capsules, pet nutrition), estimated annual volumes, target launch dates, and packaging specifications.
B. Regulatory & Technical Compliance Data
During formal onboarding and technology transfer, we collect technical documentation necessary for batch record generation under 21 CFR Part 111 and Part 117 regulations, such as raw material master files, Certificate of Analysis (CoA) requirements, and label claim specifications.
C. Technical & Infrastructure Logs
When accessing our web portals, standard server logs automatically record technical data necessary for cybersecurity monitoring and load balancing. This includes IP address, browser type, operational system, referring URL, time-stamp logs, and interaction indicators. This technical telemetry is processed purely for site performance, anti-spam validation, and operational integrity.
3. How Information Is Processed & Leveraged
PAG Pharmatech America processes information strictly for legitimate commercial and regulatory purposes directly connected to dietary supplement manufacturing services:
- RFQ Evaluation & Formulation Feasibility: Reviewing incoming active ingredients, dosage requirements, and cost-per-serving calculations.
- cGMP Batch Execution & Quality Documentation: Generating Master Manufacturing Records (MMR), batch release files, and CoAs compliant with US FDA and international standards.
- International Regulatory Support: Assisting client brands with Supplement Facts panel formatting, allergen declarations, and international shipping documentation (EU-GMP, Halal, Kosher verification).
- Client Relationship Management: Transmitting order updates, production schedules, stability testing results, and freight tracking information.
We do not utilize client contact information for consumer advertising, retargeting list sales, or unauthorized secondary communications.
4. Non-Disclosure, Data Sharing & Operational Boundaries
PAG Pharmatech America maintains a strict non-disclosure baseline. We do not sell, rent, broker, or trade client information or consumer data to third-party brokers, marketing networks, or list managers.
Limited Operational Disclosures
Information is shared only under strict operational boundaries necessary to complete contract manufacturing commitments:
- ISO-Accredited Testing Laboratories: Sample analytical data may be shared with accredited third-party laboratories for heavy metal, potency, and microbiological release testing under strict confidentiality.
- Logistics & 3PL Partners: Shipping addresses, custom declarations, and pallet manifests are provided to freight carriers and warehouse hubs to facilitate direct delivery.
- Legal & Regulatory Mandates: Disclosure may occur if explicitly required by US Federal law, subpoena, FDA inspection request, or judicial order.
5. Global Data Protection & International Compliance
Because PAG operates an integrated global manufacturing system (USA, Netherlands, and Asia-Pacific operations), we align our data architecture with internationally recognized data protection frameworks:
- European Union GDPR Alignment: We respect rights regarding personal data processing, access requests, rectification, and erasure for EU-based corporate representatives.
- California Privacy Rights (CCPA / CPRA): California residents hold statutory rights regarding data collection disclosure, non-discrimination, and deletion rights.
- Cross-Border Security: International data transfers across PAG group facilities utilize encrypted channels and standard contractual clauses (SCCs) to ensure consistent security protocols worldwide.
6. Digital Cookies & Telemetry Guidelines
Our website utilizes essential functional cookies required for system navigation, security protocol verification, and user session stability. We do not deploy intrusive third-party behavioral trackers or cross-site profiling scripts. Visitors can control cookie behavior through browser configuration settings; however, disabling standard cookies may impact technical site functionality.
7. Data Security Safeguards & Retention Schedules
PAG implements comprehensive physical, administrative, and electronic safeguards to prevent unauthorized data access, loss, or alteration:
- Digital Controls: 256-bit SSL encryption for data in transit, firewalled server environments, and role-based access controls for corporate databases.
- Physical Security: Controlled access cleanrooms, biometric entry for quality laboratories, and monitored warehousing in our Springville facility.
- Retention Policies: Commercial inquiry records are maintained for 24 months. cGMP production records, Master Batch files, and laboratory testing logs are retained for the mandatory statutory timelines mandated by FDA 21 CFR Part 111 rules.
8. Policy Updates & Contact Verification
PAG Pharmatech America reserves the right to revise this Privacy Policy periodically to reflect operational, legal, or regulatory updates. Revisions will be published directly to this page with an updated modification date.
