PEARL Group LLC - Privacy Policy

Effective Date: May 5, 2026

Pearl Group LLC operates a membership-based group purchasing organization (“GPO”) serving research practitioners, clinics, and health organizations. This Privacy Policy describes how Pearl collects, uses, discloses, retains, and protects personal information in connection with its website (https://pearlgpo.com), membership portal, and all related services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read and understood this Policy.

This Policy applies to prospective members, current members, referral partners, vendors, and all other individuals who interact with Pearl’s Services. It does not apply to information collected by third parties through their own websites or services.

1. Information We Collect

We collect personal information in the following categories:

1.1 Information You Provide Directly

Identity and Contact Data: full name, job title, organization name, professional license or credential number, mailing and billing address, telephone number, email address, and fax number.
Account Credentials: username, password (stored in hashed form), used to access the member portal.
Membership and Enrollment Data: membership tier selected, application information, signed membership agreements, referral source, and related onboarding documents.
Purchase and Transaction Data: order history, product selections, shipping addresses, invoices, and records of research compound procurement through Pearl’s GPO contracts.
Payment Information: billing name, billing address, and payment card or ACH details. Pearl uses PCI-DSS-compliant third-party payment processors; we do not store full card numbers on our own servers.
Communications: messages, inquiries, support tickets, survey responses, and other communications you send to Pearl.

1.2 Information Collected Automatically

Log and Device Data: IP address, browser type and version, operating system, device identifiers, referring/exit URLs, pages visited, and timestamps.
Usage Data: features accessed within the member portal, search queries, click-stream data, and session duration.
Cookies and Tracking Technologies: Pearl uses cookies, web beacons, and similar technologies to support site functionality, remember your preferences, and analyze aggregate usage patterns. See our Cookie Policy at https://pearlgpo.com/cookie-policy/ for full details and opt-out instructions.
Analytics: Pearl uses third-party analytics services that collect anonymized, aggregated data about how visitors use the site.

1.3 Information Received from Third Parties

Referral Partner Data: if a referral partner registers or refers you to Pearl, we may receive your name and contact information from them.
Professional Verification Services: we may verify your professional credentials or license status through third-party verification databases.
Social and Professional Networks: if you connect a LinkedIn or other professional account to your Pearl profile, we receive the information you authorize for sharing.

2. How We Use Your Information

Pearl uses personal information for the following purposes, each supported by an appropriate legal basis:

2.1 Membership Services and Operations

To evaluate membership applications and enroll qualified practitioners.
To administer your account, authenticate your identity, and provide access to the member portal.
To fulfill orders, manage procurement relationships, and coordinate delivery of research compounds through our vendor network.
To communicate order status, shipping confirmations, invoices, and account notifications.
To maintain required records of administrative fees, member attributions, and purchase volumes as required by applicable law and vendor contracts.

2.2 Communications and Member Support

To respond to your inquiries, support tickets, and requests.
To send transactional emails (order confirmations, account alerts, membership renewal notices).
To send promotional communications about new products, member benefits, educational resources, and special offers — where you have provided consent or where permitted by applicable law. You may opt out at any time (see Section 7).
To conduct member satisfaction surveys and collect feedback to improve our Services.

2.3 Safety, Compliance, and Legal Obligations

To verify professional credentials and ensure research compound procurement is limited to qualified practitioners.
To detect, investigate, and prevent fraud, misuse, or unauthorized access to our Services.
To comply with applicable federal and state laws, including record-keeping obligations under applicable pharmacy, research, and business regulations.
To respond to lawful requests from government authorities, regulatory agencies, or courts.
To enforce our Terms and Conditions, membership agreements, and other contractual obligations.

2.4 Business Operations and Improvement

To analyze usage patterns, conduct internal research, and improve the functionality and content of our Services.
To develop new features, programs, and member benefits.
To perform internal recordkeeping, financial reconciliation, and auditing.

3. How We Share Your Information

Pearl does not sell your personal information to third parties. We share personal information only in the limited circumstances described below.

3.1 Vendors and Service Providers

We share information with trusted third-party vendors who process data on our behalf, including payment processors, cloud hosting and data storage providers, email delivery and marketing platforms, analytics and performance monitoring tools, CRM software, and professional credential verification services. These vendors are contractually required to protect your information and use it only for services they provide to Pearl.

3.2 Vendor Partners

To fulfill your orders, Pearl shares relevant member information (such as name, shipping address, and purchase data) with our supply chain and vendor partners. These partners are required to maintain the confidentiality of such information.

3.3 Referral Partners

If you were referred to Pearl through our referral partner program, we may confirm your membership status and basic account information to the referring partner, consistent with your membership agreement.

3.4 Legal and Compliance Disclosures

In response to a valid subpoena, court order, or legal process.
To comply with requests from government or regulatory authorities, including the FDA, Department of Health and Human Services or state regulatory bodies.
To protect the rights, property, or safety of Pearl, our members, or the public.

3.5 Business Transfers

If Pearl is involved in a merger, acquisition, reorganization, or sale of all or a portion of its assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website if your information becomes subject to a different privacy policy.

4. Data Retention

Pearl retains your personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Active member account data: retained for the duration of your membership and for seven (7) years following membership termination.
Transaction and order records: retained for seven (7) years from the date of the transaction, consistent with tax, financial, and regulatory requirements.
Communications and support records: retained for three (3) years from the date of last communication.
Website analytics and log data: retained for up to twenty-four (24) months, after which it is aggregated or deleted.
Marketing preferences and consent records: retained for three (3) years from the date of last interaction or until you withdraw consent.

When personal information is no longer required, we securely delete or anonymize it in accordance with our internal data disposal standards.

5. Security of Your Information

Pearl implements commercially reasonable physical, electronic, and administrative safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security practices include:

Encrypted data transmission using Transport Layer Security (TLS/HTTPS) across our website and member portal.
Password hashing using industry-standard one-way cryptographic algorithms; plaintext passwords are never stored.
Role-based access controls limiting staff access to personal information on a need-to-know basis.
Regular security assessments and vulnerability monitoring of our systems.
PCI-DSS-compliant third-party payment processing.
Employee training on data handling, confidentiality obligations, and security best practices.

No method of electronic storage or transmission is completely secure. In the event of a data breach that is likely to result in harm to you, we will notify you as required by applicable state and federal law.

6. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information. Pearl is committed to honoring these rights.

6.1 Rights Available to All Users

Access: You may request a copy of the personal information Pearl holds about you.
Correction: You may request that we correct inaccurate or incomplete personal information.
Deletion: You may request that we delete your personal information, subject to our legal obligations to retain certain records.
Portability: In certain circumstances, you may request your personal information in a structured, machine-readable format.
Objection to Marketing: You may opt out of marketing communications at any time (see Section 7).

6.2 California Residents — CCPA/CPRA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (as amended by the California Privacy Rights Act, “CCPA/CPRA”):

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected, sources, purposes, and categories of third parties with whom we share it.
Right to Delete: Request deletion of personal information we have collected, subject to certain legal exceptions.
Right to Correct: Request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale or Sharing: Pearl does not sell personal information. If our practices change, we will provide a prominent “Do Not Sell or Share My Personal Information” link on our homepage.
Right to Limit Use of Sensitive Personal Information: To the extent Pearl collects sensitive personal information as defined by CPRA, you may limit its use to purposes specified by law.
Right to Non-Discrimination: Pearl will not discriminate against you for exercising any CCPA/CPRA rights.

To submit a California privacy rights request, contact us at support@pearlgpo.com or (858) 215-3433. We will verify your identity before processing your request. California residents may also designate an authorized agent to submit requests on their behalf.

6.3 Other State Privacy Rights

Residents of Colorado, Connecticut, Virginia, Texas, Oregon, Montana, and other states that have enacted comprehensive privacy laws may have similar rights to access, correct, delete, or port their personal information. Pearl will honor requests submitted under applicable state law. Contact us at support@pearlgpo.com to submit a request.

7. Marketing Communications and Opt-Out

Pearl may send you promotional emails, newsletters, and information about new products and member benefits. All marketing emails include a clear “Unsubscribe” link. You may opt out by:

Clicking the “Unsubscribe” link in any marketing email you receive from Pearl.
Emailing us at hello@pearlgpo.com with “Unsubscribe” in the subject line.
Calling us at (858) 215-3433 during business hours.

Even if you opt out of marketing communications, we will continue to send transactional and account-related messages (order confirmations, membership renewal notices, security alerts) necessary to provide the Services.

8. Cookies and Tracking Technologies

Our website and member portal use cookies and similar tracking technologies to enhance functionality, remember your preferences, and analyze site performance. We use the following categories of cookies:

Strictly Necessary Cookies: Required for the website to function. These cannot be disabled without affecting core features such as account login, session management, and security.
Preference Cookies: Allow us to remember your settings and preferences across sessions.
Analytics Cookies: Collect anonymized data about how visitors use our site to help us improve performance and content.
Marketing Cookies: Used to deliver relevant advertising and track campaign effectiveness. These are only placed with your consent.

You may manage your cookie preferences through the consent banner displayed when you visit our site, or through your browser settings.

9. Third-Party Links and Services

Our website and member portal may contain links to third-party websites, resources, and services (including professional associations, vendor portals, and educational platforms). Pearl is not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to information collected by Pearl through its own Services.

10. Changes to This Privacy Policy

Pearl reserves the right to modify this Privacy Policy at any time. When we make material changes, we will:

Update the “Effective Date” at the top of this Policy.
Post the revised Policy on our website at https://pearlgpo.com/privacy-policy/.
Send a notice to the email address associated with your account when changes are significant.

Your continued use of the Services after the effective date of any revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.