ProtoGen, Inc. – Privacy Policy

Applicable to protogen.com and the GridNav Platform

Effective Date: 03/10/2026  |  Last Revised: 03/10/2026

ProtoGen, Inc. (“ProtoGen,” “we,” “us,” or “our”) operates the ProtoGen website at https://www.protogen.com and the GridNav energy infrastructure platform (collectively, the “Services”). This Privacy Policy explains how we collect, use, disclose, and protect information about you when you use our Services, and describes the choices you have regarding your information.

This Privacy Policy is incorporated by reference into our Terms of Use, which govern your use of the Services. By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please discontinue use of the Services.

This policy applies to all users of the Services, including visitors to the ProtoGen website, registered GridNav users, organizational account holders, and individuals whose information is submitted through the Services by an organization.

1      Information We Collect

We collect information in three ways: information you provide directly, information collected automatically when you use the Services, and information received from third parties.

1.1       Information You Provide Directly

When you interact with the Services, you may provide us with the following categories of information:

• Contact and account information: name, job title, organization name, email address, phone number, and mailing address, collected when you register for an account, contact us, or complete a form on our website.
• Billing and subscription information: billing address and payment method details, collected when you subscribe to GridNav. Payment card data is processed directly by our payment processor and is not stored by ProtoGen.
• Project and energy data: energy load profiles, site characteristics, utility rate information, cost assumptions, interconnection parameters, incentive eligibility data, and other project-specific inputs that you upload or enter into GridNav to generate feasibility analyses.
• Communications: the content of messages, inquiries, support requests, feedback, or other communications you send to us.
• Survey and research responses: information you provide if you participate in user research, surveys, or beta feedback programs.

1.2     Information Collected Automatically

When you access the Services, we and our service providers automatically collect certain technical and usage information:

• Log data: your IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visits, and time spent on pages.
• Device information: device type, hardware model, and unique device identifiers.
• Usage data: features accessed, queries submitted, analyses run, reports generated, and other interaction data within GridNav.
• Cookies and similar technologies: session identifiers, preference settings, and analytics data collected through cookies and similar tracking technologies. See Section 4 for details.
• AI Analysis interaction data: queries submitted to GridNav’s AI Analysis features, the model outputs returned, and feedback signals such as thumbs up/down ratings, if provided.

1.3     Information from Third Parties

We may receive information about you from third-party sources, including:

• Data providers: publicly available utility rate data, grid interconnection data, geographic and parcel data, and energy pricing data integrated into GridNav from third-party sources.
• Analytics and advertising partners: aggregate demographic and behavioral data from analytics platforms.
• Referral sources: if you were referred to the Services by a partner organization, we may receive your name and contact information from that partner.

2    How We Use Your Information

We use the information we collect for the following purposes:

2.1     Providing and Operating the Services

• Creating and managing your account.
• Processing subscription payments and managing billing.
• Running feasibility models, generating analyses, and delivering GridNav Outputs based on your project inputs.
• Delivering AI Analysis features, including generating text-based observations and project recommendations.
• Sending transactional communications such as account confirmations, invoices, and service notifications.

2.2     Improving and Developing the Services

• Analyzing usage patterns to understand how features are used and to identify opportunities for improvement.
• Diagnosing technical issues, debugging errors, and monitoring service performance.
• Developing new features, tools, and capabilities based on user behavior and feedback.
• Evaluating and improving the accuracy and quality of AI Analysis outputs. ProtoGen may use anonymized and aggregated interaction data to assess model performance. We do not use identifiable project data to retrain AI models without your consent.

2.3     Communications and Support

• Responding to your inquiries, support requests, and feedback.
• Sending product updates, feature announcements, and educational content related to the Services, where you have not opted out.
• Conducting user research and surveys, where you have chosen to participate.

2.4   Legal, Security, and Compliance

• Detecting, investigating, and preventing fraud, unauthorized access, and other harmful or illegal activity.
• Enforcing our Terms of Use and other applicable agreements.
• Complying with applicable legal obligations, including responding to lawful government requests and legal process.
• Protecting the rights, property, and safety of ProtoGen, our users, and the public.

2.5    Aggregated and De-identified Data

ProtoGen may use aggregated, anonymized, and de-identified data derived from the Services for industry research, benchmarking, product development, and public reporting. Such data does not identify any individual user or organization and is not subject to this Privacy Policy.

3    How We Share Your Information

ProtoGen does not sell your personal information. We do not share your information with third parties for their own marketing purposes. We share information only in the following circumstances:

3.1     Service Providers

We share information with third-party companies and individuals that perform services on our behalf. These service providers are contractually obligated to use your information only for the purpose of providing services to ProtoGen and are prohibited from using it for independent purposes. Categories of service providers include:

• Cloud hosting and infrastructure providers that store and process data on ProtoGen’s behalf.
• Payment processors that handle subscription billing. Payment processors operate under their own PCI-compliant security environments and do not share card data with ProtoGen.
• AI infrastructure providers whose large language model services power GridNav’s AI Analysis features. Queries submitted to AI Analysis are processed by these providers subject to data processing agreements with ProtoGen.
• Analytics platforms that help us understand how the Services are used.
• Customer support and communication tools used to manage user inquiries and outreach.

3.2    Legal Requirements and Safety

We may disclose your information if we believe in good faith that such disclosure is necessary to: (a) comply with a legal obligation, court order, or lawful government request; (b) enforce our Terms of Use or other agreements; (c) protect the rights, property, or safety of ProtoGen, our users, or the public; or (d) detect, prevent, or address fraud, security, or technical issues.

Where legally permitted and practicable, ProtoGen will notify affected users before disclosing information in response to legal process, unless prohibited from doing so by law or court order.

3.3    Business Transfers

If ProtoGen is involved in a merger, acquisition, asset sale, or other corporate transaction, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

3.4   With Your Consent

We may share your information with third parties when you have given us explicit consent to do so, such as when you request a referral to a partner organization or participate in a co-branded program.

3.5    Organizational Accounts

If you access the Services through an organizational account, the organization that administers your account may have access to your usage data, project data, and account information within GridNav. ProtoGen’s obligations run to the account administrator, and users within an organizational account should review their organization’s internal policies regarding data access.

4   Cookies and Tracking Technologies

4.1     What We Use

We use cookies and similar tracking technologies on the Services. Cookies are small text files stored on your device. We use the following categories of cookies:

• Strictly necessary cookies: required for the Services to function, including session authentication and security tokens. These cannot be disabled without breaking core functionality.
• Functional cookies: remember your preferences and settings, such as language or display options.
• Analytics cookies: help us understand how visitors use the Services, which pages are most visited, and where users encounter errors. We use tools such as Google Analytics for this purpose. Analytics data is aggregated and does not identify individual users by name.
• Performance cookies: monitor service performance and uptime.

4.2   Your Cookie Choices

You can instruct your browser to refuse all cookies or to notify you when a cookie is being sent. However, if you disable strictly necessary cookies, some portions of the Services, including GridNav account access, will not function correctly. Instructions for managing cookies are available in your browser’s help documentation.

For Google Analytics specifically, you may opt out of tracking by installing the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

4.3   Do Not Track

Some browsers transmit a “Do Not Track” signal. The Services do not currently respond to Do Not Track signals because there is no industry-standard interpretation of what such signals require. We will revisit this position if a standard emerges.

5    Data Storage, Retention, and Security

5.1     Storage Location

ProtoGen stores data on servers located in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Services, you consent to this transfer.

5.2    Retention Schedule

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following:

• Account data is retained for the duration of your active account and for up to three years following account termination, to support dispute resolution, audit obligations, and legal compliance.
• Project data and GridNav Outputs are retained for the duration of your active subscription. Following account termination, project data is deleted or anonymized within 90 days, unless you request earlier deletion or we are required by law to retain it longer.
• AI Analysis interaction data in anonymized and aggregated form may be retained indefinitely for product improvement purposes.
• Billing records are retained for seven years to comply with tax and accounting obligations.
• Log data is retained for up to 12 months.

5.3    Security Measures

ProtoGen implements reasonable and appropriate technical and organizational security measures designed to protect your information against unauthorized access, loss, alteration, or disclosure. These measures include encrypted data transmission (TLS), access controls, authentication requirements, and regular security assessments.

However, no method of data transmission or electronic storage is completely secure. ProtoGen cannot guarantee absolute security, and you use the Services at your own risk with respect to security. If you believe your account has been compromised, please contact us immediately at Contact@ProtoGen.com.

5.4   Data Breach Notification

In the event of a data breach that is reasonably likely to result in risk to your rights and freedoms, ProtoGen will notify affected users without undue delay and, where required, will notify applicable regulatory authorities. Notification will be provided via email to the address associated with your account and/or by prominent notice on the Services.

6    AI Analysis Features and Your Data

GridNav includes AI Analysis features that generate text-based observations, summaries, and project recommendations. This section explains how your data is handled in connection with these features.

6.1     How AI Analysis Processes Your Data

When you use AI Analysis features, your project inputs, modeling outputs, and contextual data are submitted to AI language model infrastructure to generate a response. This processing occurs in real time. The AI model does not retain memory of your specific inputs between separate sessions.

6.2   AI Infrastructure Providers

AI Analysis is powered by third-party large language model providers operating under data processing agreements with ProtoGen. These providers process your query data solely to generate the requested response on ProtoGen’s behalf. ProtoGen selects providers that maintain enterprise-grade data handling practices, including restrictions on using customer data to train their general-purpose models without consent.

6.3   ProtoGen’s Use of AI Interaction Data

ProtoGen may review anonymized AI Analysis interaction data, including anonymized queries and outputs, for the purpose of evaluating model quality, identifying errors, and improving the configuration of AI Analysis features. ProtoGen does not use identifiable project data or personally identifiable information to train or fine-tune AI models without your explicit consent.

6.4  Limitations You Should Understand

AI Analysis outputs are generated by probabilistic models and may contain inaccuracies. You should not include confidential third-party information, personal health information, financial account numbers, or other highly sensitive data in AI Analysis queries unless you are comfortable with that data being processed by AI infrastructure as described above. ProtoGen is not responsible for information you choose to include in AI Analysis inputs.

7    Government and Institutional Users

ProtoGen serves government clients including municipal utilities, tribal governments, state agencies, and federal agencies. If you access the Services as a government or institutional user, the following additional terms apply:

• ProtoGen will honor any data handling requirements specified in an executed contract, data use agreement, or memorandum of understanding between ProtoGen and your organization. In the event of a conflict between this Privacy Policy and a fully executed data agreement, the data agreement controls.
• ProtoGen does not assert ownership over project data submitted by government clients. All project data remains the property of the submitting organization.
• Government clients with specific data residency, retention, or security requirements beyond those described in this Privacy Policy should contact us at Contact@ProtoGen.com before submitting sensitive project data through the Services.
• ProtoGen will cooperate with government clients in responding to public records requests to the extent consistent with applicable law and with the confidentiality protections in our agreements.

8    Your Rights and Choices

ProtoGen respects your ability to control your information. The following rights and choices are available to all users:

8.1     Access and Correction

You may request a copy of the personal information ProtoGen holds about you, and you may request correction of inaccurate information, by contacting us at Contact@ProtoGen.com. We will respond to verified requests within 30 days.

8.2   Deletion

You may request deletion of your personal information by contacting us at Contact@ProtoGen.com. We will honor deletion requests subject to our legal obligations to retain certain data (such as billing records) and our legitimate interest in maintaining account security during any dispute resolution period. Following a valid deletion request, we will delete or anonymize your information within 90 days.

8.3   Data Portability

You may request an export of your GridNav project data in a machine-readable format by contacting us at Contact@ProtoGen.com. We will make reasonable efforts to fulfill portability requests within 30 days.

8.4  Opt-Out of Marketing Communications

You may opt out of receiving non-transactional marketing emails from ProtoGen at any time by clicking the unsubscribe link in any marketing email or by contacting us at Contact@ProtoGen.com. You will continue to receive transactional communications necessary to maintain your account even if you opt out of marketing.

8.5   California and Oregon Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know, the right to delete, and the right to opt out of the sale of personal information. ProtoGen does not sell personal information. To exercise your CCPA rights, contact us at Contact@ProtoGen.com.

If you are an Oregon resident, you may have rights under the Oregon Consumer Privacy Act (OCPA), effective July 1, 2024, including the right to access, correct, delete, and obtain a portable copy of your personal data. To exercise your OCPA rights, contact us at Contact@ProtoGen.com. ProtoGen will respond to verified requests within 45 days, with a possible 45-day extension where reasonably necessary.

8.6   Account Closure

You may close your GridNav account at any time by contacting us at Contact@ProtoGen.com. Following account closure, your data will be handled in accordance with the retention schedule in Section 5.2.

9    Third-Party Links and Integrations

The Services may contain links to third-party websites or integrate with third-party data services. This Privacy Policy applies only to the Services operated by ProtoGen. Third-party sites and services have their own privacy policies, which we encourage you to review. ProtoGen is not responsible for the privacy practices of third-party sites or services, including those integrated into GridNav such as utility data providers, GIS data sources, or DOE modeling tools.

10  Children’s Privacy

The Services are not directed to children under the age of 18, and ProtoGen does not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided personal information to ProtoGen, please contact us at Contact@ProtoGen.com and we will promptly delete that information from our records.

11   Changes to This Privacy Policy

ProtoGen may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable law. If we make material changes, we will notify you by sending an email to the address associated with your account and by posting a prominent notice on the Services at least 30 days before the changes take effect. The updated policy will identify its effective date.

Your continued use of the Services after the effective date of a revised Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the revised policy, you must discontinue use of the Services.

We maintain an archive of prior versions of this Privacy Policy, which is available upon request by contacting Contact@ProtoGen.com.

12  Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

ProtoGen, Inc.

PO Box 193

Quakertown, PA 18951

Email: Contact@ProtoGen.com

Phone: (888) 365-4743

Website: https://www.protogen.com

We will make reasonable efforts to respond to all privacy inquiries within 30 days of receipt.

Effective Date: 3/10/2026

Copyright © 2026 ProtoGen, Inc. All rights reserved.