Privacy policy

PRIVACY NOTICE FOR U.S. USERS

Effective Date: September 3, 2026
Last Updated: September 9, 2026 Version 1.0

NexFor International Inc., operating under the TREGEN brand (“TREGEN,” “we,” “us,” or “our”), respects your privacy and is committed to handling personal information in a transparent, reasonable, and secure manner.

This Privacy Notice explains how we collect, use, disclose, share, retain, and protect personal information when you visit the TREGEN website, purchase products, create an account, submit an inquiry, request warranty or customer support, subscribe to marketing communications, interact with our advertising, or otherwise use our website and related services.

This Privacy Notice primarily applies to:

https://www.tregen.net

and other TREGEN websites and online services controlled by NexFor International Inc. and directed to users and customers in the United States.

 

 

1. SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice is intended for website visitors, consumers, and customers located in the United States.

It may apply when you:

  • visit the TREGEN website;

  • create an online account;

  • purchase TREGEN products;

  • add products to a shopping cart;

  • submit a product inquiry;

  • contact customer service;

  • request warranty or after-sales support;

  • register a product;

  • subscribe to newsletters or product information;

  • participate in promotions or marketing activities;

  • interact with digital advertising;

  • or use website analytics or other online features.

This Privacy Notice is designed to address applicable U.S. federal and state privacy laws.

Whether a particular state privacy law applies to TREGEN depends on the applicable legal thresholds, TREGEN's business activities, the consumer's state of residence, the volume and nature of personal information processed, and how that information is used.

This Privacy Notice is not intended to describe rights arising under European Union, United Kingdom, Canadian, Brazilian, Taiwanese, or other non-U.S. privacy laws.

 

 

2. WHO WE ARE

The TREGEN website and related services are operated by:

NexFor International Inc.
Brand: TREGEN

Level 2, Lotemau Centre Building
Vaea Street
Apia, Samoa

Email:
[email protected]

Telephone:
(+886) 2-2681-7338

Website:
https://www.tregen.net

Although NexFor International Inc. is registered in Samoa, this Privacy Notice specifically describes how TREGEN handles personal information in connection with services directed to users and customers in the United States.

Depending on applicable U.S. state law, NexFor International Inc. may be referred to as a “business,” “controller,” or similar regulated entity.

 

 

3. WHAT “PERSONAL INFORMATION” MEANS

For purposes of this Privacy Notice, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual, household, or device where applicable under law.

Personal information may include information that directly identifies you, such as your name or email address, as well as information that may identify or distinguish you when combined with other information, such as:

  • IP addresses;

  • device identifiers;

  • cookie identifiers;

  • purchase history;

  • account information;

  • online activity;

  • and certain location information.

Personal information generally does not include information that has been lawfully made public, aggregated information that cannot reasonably be linked to an individual, or information that has been properly de-identified in accordance with applicable law.

 

 

4. PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with TREGEN.

4.1 Identifiers and Contact Information

We may collect:

  • name;

  • email address;

  • telephone number;

  • mailing address;

  • billing address;

  • shipping address;

  • account name;

  • customer identifier;

  • IP address;

  • and similar online identifiers.

Unless necessary for a specific transaction, legal requirement, identity verification, or security purpose, we do not ask ordinary website visitors to provide:

  • Social Security numbers;

  • passport numbers;

  • driver's license numbers;

  • or other government-issued identification numbers.

 

 

4.2 Account Information

If account functionality is available, we may process:

  • account name;

  • account identifier;

  • login activity;

  • account preferences;

  • language settings;

  • communication preferences;

  • registered products;

  • and account activity.

Passwords should be protected using appropriate security measures and should not be stored in ordinary readable plain-text form.

 

 

4.3 Commercial and Transaction Information

We may collect:

  • purchase history;

  • order details;

  • SKU numbers;

  • product model numbers;

  • purchase dates;

  • order values;

  • payment status;

  • transaction identifiers;

  • shipping information;

  • return information;

  • refund information;

  • warranty records;

  • after-sales service records;

  • and customer service history.

Where payments are handled by a third-party payment processor, TREGEN generally does not directly retain complete payment card numbers or CVV/CVC security codes.

 

 

4.4 Internet and Device Information

When you use our website, we may automatically collect:

  • IP address;

  • browser type;

  • browser version;

  • operating system;

  • device type;

  • language settings;

  • time zone;

  • cookie identifiers;

  • session identifiers;

  • referral URLs;

  • pages viewed;

  • search activity;

  • time spent on pages;

  • click activity;

  • shopping cart activity;

  • conversion events;

  • technical error information;

  • and other website or electronic network activity information.

 

 

5. GEOLOCATION INFORMATION

TREGEN may use an IP address to determine an approximate location, such as:

  • country;

  • state;

  • city;

  • or approximate geographic area.

The ordinary TREGEN website does not require precise GPS location merely because you visit the website.

If a future website feature requires precise geolocation, we will provide any legally required notice and obtain consent where required by applicable law.

 

 

6. COMMUNICATIONS AND CUSTOMER SERVICE INFORMATION

If you contact TREGEN, we may collect and retain:

  • emails;

  • website contact forms;

  • customer service communications;

  • technical questions;

  • product inquiries;

  • warranty requests;

  • complaints;

  • product photographs;

  • malfunction or defect information;

  • attachments you voluntarily provide;

  • and other communications.

Please do not send sensitive personal information unless it is reasonably necessary for us to address your request.

 

 

7. MARKETING AND PREFERENCE INFORMATION

We may process information relating to:

  • newsletter subscriptions;

  • marketing consent;

  • email opens;

  • email clicks;

  • advertising interactions;

  • cookie preferences;

  • product interests;

  • and opt-out records.

 

 

8. INFERENCES

Where applicable, we may use:

  • website activity;

  • purchase history;

  • advertising interactions;

  • and product browsing activity;

to infer general product interests or market preferences.

We do not use these activities for the purpose of creating sensitive profiles relating to:

  • health conditions;

  • religious beliefs;

  • race or ethnicity;

  • political views;

  • sexual orientation;

  • or other highly sensitive personal characteristics.

 

 

9. SENSITIVE PERSONAL INFORMATION

Certain U.S. privacy laws give additional protection to information considered “Sensitive Personal Information” or “Sensitive Data.”

TREGEN's ordinary website does not generally seek to collect:

  • Social Security numbers;

  • government identification numbers;

  • complete financial authentication credentials;

  • race or ethnicity;

  • religious beliefs;

  • medical diagnoses;

  • genetic data;

  • biometric data used for identification;

  • precise geolocation;

  • sexual orientation;

  • or information concerning a person's sex life.

If a TREGEN service later needs to process information classified as sensitive under applicable law, we will, as appropriate:

  1. limit the processing to what is reasonably necessary;

  2. provide appropriate notice;

  3. obtain consent where legally required;

  4. provide applicable rights to limit, withdraw consent, or opt out;

  5. and apply safeguards appropriate to the sensitivity of the information.

 

 

10. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information from the following sources.

Information You Provide Directly

For example, when you:

  • create an account;

  • purchase a product;

  • submit an inquiry;

  • contact customer service;

  • request warranty support;

  • subscribe to marketing;

  • or participate in an activity or promotion.

Automated Technologies

We may collect information through:

  • cookies;

  • pixels;

  • web beacons;

  • server logs;

  • local storage;

  • analytics technologies;

  • and similar online tools.

Service Providers

We may receive information from providers that support:

  • e-commerce;

  • payments;

  • logistics;

  • CRM;

  • email services;

  • website hosting;

  • analytics;

  • customer support;

  • and security.

Advertising and Marketing Partners

If TREGEN uses Google, Meta, or other advertising platforms, we may receive information relating to:

  • advertising performance;

  • conversions;

  • campaign interactions;

  • and related analytics.

 

 

11. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes.

Orders and Services

To:

  • process orders;

  • confirm transactions;

  • manage payment status;

  • arrange shipment;

  • manage customer accounts;

  • and maintain transaction records.

Customer Service and After-Sales Support

To:

  • answer product questions;

  • provide technical support;

  • process warranties;

  • manage returns and refunds;

  • provide after-sales support;

  • issue product recalls;

  • and communicate product safety notices.

Website Operations

To support:

  • shopping cart functionality;

  • login;

  • session management;

  • security;

  • website performance;

  • error diagnosis;

  • and user experience improvements.

Security and Fraud Prevention

To:

  • detect fraud;

  • prevent malicious traffic;

  • prevent account abuse;

  • detect suspicious login activity;

  • prevent unauthorized activity;

  • and protect TREGEN, our customers, and third parties.

Analytics and Service Improvement

To perform:

  • website analytics;

  • user experience analysis;

  • performance analysis;

  • product demand analysis;

  • market analysis;

  • and advertising measurement.

Marketing

Where permitted by law, we may use information to:

  • send product information;

  • send newsletters;

  • provide promotional communications;

  • evaluate marketing campaigns;

  • measure advertising attribution;

  • conduct remarketing;

  • and support targeted advertising.

Legal and Compliance Purposes

We may use information to:

  • comply with law;

  • respond to court orders;

  • respond to lawful government requests;

  • comply with tax and accounting requirements;

  • establish, exercise, or defend legal claims;

  • and protect legal rights and property.

 

 

12. DATA MINIMIZATION AND PURPOSE LIMITATION

TREGEN seeks to limit the collection, use, and retention of personal information to what is reasonably necessary and proportionate for:

  • the purposes disclosed to you;

  • purposes reasonably expected in connection with our services;

  • or other purposes permitted by law.

We do not intend to collect personal information merely because technology makes collection possible.

If we intend to use personal information for a materially different purpose, we will provide additional notice and obtain consent where required by law.

 

 

13. COOKIES AND SIMILAR TECHNOLOGIES

TREGEN may use cookies, pixels, web beacons, local storage, and similar technologies.

Strictly Necessary Cookies

These may support:

  • website security;

  • shopping cart functionality;

  • login;

  • session management;

  • privacy preferences;

  • and core site functions.

Functional Cookies

These may remember:

  • language;

  • region;

  • website preferences;

  • and user settings.

Analytics Cookies

These may be used for:

  • website traffic measurement;

  • page performance;

  • user interaction analysis;

  • and website improvement.

Advertising Cookies

If enabled, these may be used for:

  • conversion measurement;

  • advertising attribution;

  • remarketing;

  • targeted advertising;

  • and cross-context behavioral advertising.

Where required by applicable law, we will provide appropriate choices regarding non-essential cookies.

 

 

14. ANALYTICS AND ADVERTISING TECHNOLOGIES

If TREGEN deploys services such as:

  • Google Analytics;

  • Google Ads;

  • Meta Pixel;

  • or similar analytics or advertising tools;

those providers may process:

  • IP addresses;

  • cookie identifiers;

  • device information;

  • browser information;

  • page views;

  • interaction events;

  • conversion events;

  • and advertising interaction information.

Under some U.S. state privacy laws, disclosures made through advertising technologies may qualify as:

  • a “sale”;

  • “sharing”;

  • targeted advertising;

  • or cross-context behavioral advertising;

even where TREGEN does not receive direct monetary payment.

Where required, TREGEN will provide applicable privacy choices and opt-out mechanisms.

 

 

15. HOW WE DISCLOSE PERSONAL INFORMATION

TREGEN does not indiscriminately make personal information publicly available.

We may disclose personal information to the following categories of recipients for legitimate business or legal purposes.

Service Providers and Processors

Including providers of:

  • website hosting;

  • cloud services;

  • Shopify or other e-commerce services;

  • payment processing;

  • shipping and logistics;

  • CRM;

  • email services;

  • customer support;

  • IT;

  • cybersecurity.

Analytics Providers

To help analyze website performance and usage.

Advertising Partners

Where TREGEN uses advertising, remarketing, or targeted advertising technologies.

Professional Advisors

Such as:

  • attorneys;

  • accountants;

  • auditors;

  • and insurers.

Government and Legal Authorities

Where required by law, court order, subpoena, or other lawful process.

Corporate Transactions

If NexFor International Inc. is involved in a:

  • merger;

  • acquisition;

  • reorganization;

  • financing;

  • asset sale;

  • or business transfer;

personal information may be transferred as part of that transaction where permitted by law.

 

 

16. SALE, SHARING, AND TARGETED ADVERTISING

TREGEN does not operate a traditional business model in which customer lists are sold for direct monetary payment.

However, certain U.S. state privacy laws define “sale” or “sharing” more broadly.

Accordingly, disclosures involving:

  • advertising cookies;

  • pixels;

  • advertising identifiers;

  • cross-site tracking;

  • or third-party advertising technologies;

may qualify as a sale, sharing, or targeted advertising activity under applicable law, even where no money is exchanged.

Where applicable, TREGEN will provide legally required opt-out rights.

 


17. YOUR PRIVACY CHOICES

Where applicable, you may manage certain privacy preferences through:

Your Privacy Choices

or

Cookie Settings

These controls may allow you to manage:

  • analytics cookies;

  • advertising cookies;

  • sale or sharing;

  • targeted advertising;

  • and other non-essential tracking technologies.

 

 

18. DO NOT SELL OR SHARE MY PERSONAL INFORMATION

If the CCPA or another applicable state law gives you the right to opt out of the sale or sharing of personal information, you may use the applicable TREGEN:

Do Not Sell or Share My Personal Information

or

Your Privacy Choices

control.

TREGEN intends for such mechanisms to be reasonably accessible and not to require unnecessary steps.

 

 

19. GLOBAL PRIVACY CONTROL

Where required by applicable law, TREGEN will recognize and process valid Global Privacy Control (GPC) or other legally recognized universal opt-out signals.

Where applicable, a valid GPC signal may serve as a request to opt out of:

  • sale;

  • sharing;

  • or targeted advertising;

for the browser or device from which the signal is received.

 

 

20. U.S. STATE PRIVACY RIGHTS

Depending on your state of residence, TREGEN's activities, and applicable statutory thresholds, you may have one or more of the following rights:

  • right to confirm whether personal information is being processed;

  • right to access personal information;

  • right to correct inaccurate information;

  • right to delete eligible personal information;

  • right to data portability;

  • right to opt out of sale;

  • right to opt out of sharing;

  • right to opt out of targeted advertising;

  • right to opt out of certain profiling;

  • rights relating to sensitive data;

  • right to withdraw consent where applicable;

  • right to appeal certain privacy request decisions;

  • and right to exercise privacy rights without unlawful discrimination.

The scope of these rights varies by state.

 

 

21. CALIFORNIA PRIVACY NOTICE

If the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), applies to TREGEN, California consumers may have the following rights.

Right to Know

You may request information regarding:

  • the categories of personal information collected;

  • the sources of that information;

  • the purposes for collection and use;

  • the categories of recipients;

  • and whether applicable information has been sold or shared.

Right to Access

You may request access to personal information that TREGEN is legally required to provide.

Right to Delete

You may request deletion of eligible personal information, subject to legal exceptions.

Right to Correct

You may request correction of inaccurate personal information.

Right to Opt Out of Sale or Sharing

You may opt out of activities that constitute sale or sharing under the CCPA.

Right to Limit Certain Uses of Sensitive Personal Information

If TREGEN uses Sensitive Personal Information in a manner that creates a statutory right to limit its use or disclosure, TREGEN will provide the required mechanism.

Right to Non-Discrimination

TREGEN will not unlawfully discriminate against you because you exercise rights granted by the CCPA.

 

 

22. CALIFORNIA 12-MONTH DISCLOSURE

To the extent required by the CCPA, the following table describes categories of personal information TREGEN may have processed during the preceding 12 months.

Category

May Be Collected

Primary Sources

Primary Business Purposes

Identifiers

Yes

Consumer / Website

Orders, accounts, support, security

Commercial Information

Yes

Consumer / Transactions

Orders, warranty, customer service

Internet / Network Activity

Yes

Website / Cookies

Security, analytics, advertising

Approximate Geolocation

Possible

IP Address

Security, regional analytics

Communications

Yes

Consumer

Customer support, warranty, inquiries

Inferences

Possible

Website / Transactions

General product-interest analysis

Sensitive Personal Information

Generally not collected through the ordinary website

Specific service only

Only where permitted and necessary

Whether any TREGEN activity constitutes a “sale” or “sharing” under the CCPA depends on the technologies actually deployed, including:

  • cookies;

  • pixels;

  • analytics platforms;

  • advertising platforms;

  • Shopify applications;

  • and other third-party tracking technologies.

 

 

23. HOW TO EXERCISE YOUR PRIVACY RIGHTS

To exercise an applicable U.S. privacy right, contact:

Email:
[email protected]

Telephone:
(+886) 2-2681-7338

You may also use any Privacy Request Form or Privacy Choices tool made available on the TREGEN website.

To protect personal information, we may request information reasonably necessary to:

  • verify your identity;

  • confirm your relationship to the relevant information;

  • and prevent unauthorized access, deletion, or disclosure.

We will not request information that is clearly excessive for verification purposes.

 

 

24. AUTHORIZED AGENTS

Where applicable law permits, you may authorize another person or entity to submit certain privacy requests on your behalf.

TREGEN may request:

  • evidence of authorization;

  • identity verification;

  • or confirmation of the agency relationship;

unless prohibited by applicable law.

 

 

25. APPEAL RIGHTS

If your state provides a right to appeal a privacy request decision, you may contact:

[email protected]

and request review of the decision.

TREGEN will process eligible appeals in accordance with applicable state law.

 

 

26. CHILDREN'S PRIVACY

TREGEN's website and towing-related products are intended primarily for adults and are not directed to children under 13.

We do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (“COPPA”).

If we learn that we have collected children's personal information in violation of applicable law, we will take reasonable steps to delete or otherwise appropriately handle that information.

 

 

27. DATA RETENTION

TREGEN retains personal information only for as long as reasonably necessary for legitimate business or legal purposes.

Relevant factors may include:

  • order fulfillment;

  • warranty periods;

  • product safety;

  • recalls;

  • customer service;

  • account duration;

  • tax and accounting requirements;

  • legal limitation periods;

  • fraud prevention;

  • information security;

  • disputes;

  • and other legal obligations.

When information is no longer reasonably necessary, TREGEN may:

  • delete it;

  • de-identify it;

  • anonymize it;

  • or otherwise dispose of it appropriately.

 

 

28. DATA SECURITY

TREGEN uses reasonable administrative, technical, and physical measures designed to reduce the risk of:

  • unauthorized access;

  • loss;

  • misuse;

  • alteration;

  • unauthorized disclosure;

  • or destruction.

Measures may include:

  • access controls;

  • authentication;

  • secure communications;

  • encryption where appropriate;

  • password protection;

  • logging;

  • monitoring;

  • backups;

  • vulnerability management;

  • vendor management;

  • and incident response procedures.

No Internet transmission, website, or information system can be guaranteed to be completely secure.

 

 

29. DATA BREACH AND SECURITY INCIDENTS

If TREGEN becomes aware of a security incident involving personal information, we may, as appropriate:

  1. investigate the incident;

  2. contain the security risk;

  3. take remediation measures;

  4. assess affected information;

  5. assess affected individuals;

  6. maintain incident records;

  7. evaluate legal notification requirements;

  8. and notify affected individuals or government authorities where required.

Applicable notification requirements and deadlines depend on relevant federal and state law.

 

 

30. INTERNATIONAL PROCESSING OF U.S. PERSONAL INFORMATION

NexFor International Inc. is registered in Samoa, and some TREGEN service providers may operate outside the United States.

Accordingly, personal information of U.S. users may be:

  • transmitted;

  • accessed;

  • stored;

  • or processed;

outside the United States.

Privacy and data protection laws in those jurisdictions may differ from U.S. law.

TREGEN will use reasonable contractual, administrative, organizational, and technical safeguards appropriate to the circumstances.

Processing personal information outside the United States does not, by itself, eliminate privacy rights that may apply to a U.S. consumer under applicable U.S. law.

 

 

31. AUTOMATED DECISION-MAKING AND PROFILING

TREGEN may use automated technologies for:

  • website analytics;

  • fraud detection;

  • general product recommendations;

  • and advertising measurement.

Unless otherwise disclosed, TREGEN does not intend to make decisions producing legal or similarly significant effects solely through automated processing.

If TREGEN later uses profiling, automated decision-making, or automated decision-making technology that creates rights under applicable law, we will provide legally required:

  • notice;

  • access;

  • opt-out rights;

  • consent mechanisms;

  • or other applicable protections.

 

 

32. THIRD-PARTY LINKS

The TREGEN website may contain links to third-party platforms or services, including:

  • Amazon;

  • Facebook;

  • Instagram;

  • YouTube;

  • Google;

  • dealers;

  • and other third-party services.

When you leave the TREGEN website, those third parties may process information under their own privacy notices.

Except where applicable law provides otherwise, TREGEN does not control independent data-processing decisions made by those third parties.

 

 

33. MARKETING COMMUNICATIONS

Where permitted by law or where necessary consent has been obtained, TREGEN may send:

  • product updates;

  • new product information;

  • promotions;

  • company news;

  • and other marketing communications.

You may unsubscribe from ordinary marketing emails at any time by using the:

Unsubscribe

link contained in the message.

Even if you unsubscribe from marketing communications, TREGEN may still send necessary transactional or service-related communications, including:

  • order confirmations;

  • warranty information;

  • product safety notices;

  • recall notices;

  • account information;

  • customer service messages;

  • and other non-marketing communications.

 

 

34. NON-DISCRIMINATION

TREGEN will not unlawfully discriminate against you because you exercise an applicable privacy right.

For example, where prohibited by law, TREGEN will not:

  • deny goods or services;

  • charge an unreasonable different price;

  • provide an unlawfully lower level of service;

  • threaten;

  • retaliate;

  • or penalize you.

Legally permitted loyalty, promotional, or financial incentive programs may be subject to separate requirements.

 

 

35. CHANGES TO THIS PRIVACY NOTICE

TREGEN may update this Privacy Notice in response to:

  • changes in law;

  • regulatory requirements;

  • website changes;

  • new technologies;

  • new services;

  • new products;

  • changes in cookies or pixels;

  • changes in advertising platforms;

  • or changes in data-processing practices.

The revised Privacy Notice will be posted on the TREGEN website and the Last Updated date will be revised.

Where required by applicable law, TREGEN will provide additional notice regarding material changes.

 

 

36. CONTACT US

If you have questions about:

  • this Privacy Notice;

  • how TREGEN handles personal information;

  • privacy rights;

  • cookies;

  • sale or sharing;

  • targeted advertising;

  • privacy requests;

  • or privacy complaints;

please contact:

NexFor International Inc.
Brand: TREGEN

Level 2, Lotemau Centre Building
Vaea Street
Apia, Samoa

Email:
[email protected]

Telephone:
(+886) 2-2681-7338

Website:
https://www.tregen.net

 

 

37. APPLICABLE U.S. PRIVACY FRAMEWORKS

Depending on TREGEN's actual business activities and applicable legal thresholds, this Privacy Notice may address requirements arising under the following laws.

U.S. Federal Law

Federal Trade Commission Act, Section 5

Including principles relating to unfair or deceptive acts or practices.

Children's Online Privacy Protection Act (COPPA)

15 U.S.C. §§ 6501 et seq.
16 C.F.R. Part 312.

California

California Consumer Privacy Act (CCPA)

California Civil Code § 1798.100 et seq., including amendments made by the California Privacy Rights Act and applicable CCPA regulations.

Other U.S. State Privacy Laws

Where statutory thresholds are satisfied, TREGEN may also be subject to other U.S. comprehensive consumer privacy laws.

Depending on the state, those laws may address:

  • access;

  • correction;

  • deletion;

  • portability;

  • sale opt-out;

  • sharing opt-out;

  • targeted advertising opt-out;

  • profiling;

  • sensitive data;

  • consent;

  • appeals;

  • and universal opt-out mechanisms.

 

 

38. APPLICABILITY OF LAWS

References to a federal or state privacy law in this Privacy Notice do not mean that every such law necessarily applies to every TREGEN activity or every website visitor.

Applicable obligations depend on factors including:

  • the consumer's state of residence;

  • NexFor International Inc.'s actual business activities;

  • applicable revenue thresholds;

  • number of consumers or households whose information is processed;

  • categories of personal information;

  • purposes of processing;

  • sale or sharing activities;

  • targeted advertising;

  • sensitive data processing;

  • profiling or automated decision-making;

  • tracking technologies;

  • and other statutory requirements.

If any provision of this Privacy Notice conflicts with a mandatory and non-waivable U.S. federal or state privacy requirement that applies to TREGEN, the applicable legal requirement will control.