Privacy policy

What we collect

When you sign up. The sign-up form asks for:

• your email address;
• your US state;
• the peptides you want to follow (the one on the page you were reading is pre-selected; you can untick it);
• which emails you want, each as its own checkbox (see the next section).

Above the checkboxes, the form says:

We'll store your email, your state, the page you're on and the peptides selected below (pre-selected from this page; untick any). Together these can reveal health interests. We use them only for what you tick below and to count sign-ups by state and peptide, without emails, to plan where the clinic opens and for reports that show only totals. Our hosting, database and email providers handle them for us. We pass them to a doctor or clinic only if you tick that box, and we don't sell them. Withdraw anytime with the unsubscribe link or at hello@ellumclinic.com. Consumer Health Data Privacy Policy

We also record the page you signed up on, the date and time, and, for each box you ticked, the exact wording you saw. That record is how we can show what you agreed to. We don't ask for your name, phone number, ZIP code, date of birth or any medical history.

If you sign up again with the same email, we keep your first sign-up's state and peptides and add the new consents to your record.

When you email us. If you write to hello@ellumclinic.com, for example to report an error or make a privacy request, we keep your email address and message to answer you and to keep a record of requests. We delete these emails 24 months after our last reply, the same limit we use for sign-ups.

When you read the site. Our own code doesn't set cookies or store your IP address; Google Analytics sets cookies (see Analytics below). Two things happen in our own code:

• Abuse protection. To limit repeated sign-up attempts, the server turns your IP address into a one-way scrambled code (a salted hash) and holds it in memory for a short time. The raw IP address is never written to our database or our logs.
• One browser setting. If a sign-up prompt slides in, your browser stores the time it was last shown (ellum.slidein.lastShownAt, in local storage) so it doesn't keep coming back. It stays in your browser; we never receive it.

Our hosting provider processes your IP address to deliver pages and may keep it in its own server logs for a short time. Google receives your IP address too, when your browser loads Google Analytics.

Analytics. Google Analytics records most pages you open and sets two first-party cookies. See Advertising and analytics for the pages it skips, exactly what it receives and how to switch it off.

Why we collect it

Each checkbox is a separate permission. We use your information for the boxes you ticked:

We also use your state and peptides to decide which emails are relevant to you. And, as the form tells you before you sign up, we count sign-ups by state and peptide (for example, how many people in each state follow a peptide) to plan where the clinic opens, to decide which updates to write, and for reports we may publish or sell. Those totals contain no email addresses, leave out any group smaller than 10 people and can't be traced back to you. We don't try to re-identify anyone, and anyone who receives a report must agree in writing not to try either.

We don't use your information for advertising on other websites or apps, and no ad platform receives it. The only ads we send are the paid offers you can tick above, and we send those ourselves. We don't make automated decisions about you. Google Analytics groups visits from the same browser under a random ID; we use that only to count visits and returning readers, and we never connect it to your email or your sign-up. We never use your information to train AI models.

Before we send any email, we'll ask you to confirm your address, so nobody can sign you up without your say-so. Sign-ups that aren't confirmed within 30 days are deleted. The confirmation email has a link to cancel the request, and every email after that has an unsubscribe link.

Consumer health data

The peptides you follow, together with your email and state, can say something about your health or the care you're looking for. We treat your whole sign-up record as consumer health data under the laws of Washington, Nevada and Connecticut, and we give the same protection to everyone, wherever you live.

Our Consumer Health Data Privacy Policy explains what we collect, why, who receives it and how to use your rights. It is the controlling text for that data.

Advertising and analytics

No advertising code. No page on Ellum loads Meta, TikTok, Google Ads or any other ad-platform pixel, tag or script. The site's security policy only lets the browser load code from our own domain and Google's tag server, and send data only to our own domain and Google's tag and analytics servers. A check we run before every release fails if ad-platform code appears. No ad platform receives what you read on Ellum.

No embedded third-party players. The site's security policy blocks players and frames from other sites.

Google Analytics. We use Google Analytics 4, from Google LLC, to count visits and see which pages are read. It doesn't load on sign-up pages (including the ones you see after sending the form), on the pages you reach from links in our emails (confirming, cancelling or unsubscribing), on a page that doesn't exist, or when the address you arrive at carries campaign tags (labels some links carry to show where they were shared). Those pages load no analytics at all. On the pages where it runs, it receives:

• the page's address and title. We send the page's address without anything after "?" or "#". Search and filter terms, link tokens and campaign tags never reach Google;
• the previous page, if it was on Ellum, or only the name of the website you came from (for example, www.google.com), never the page itself;
• when you visited and how long you spent on the page;
• browser and device details, such as browser, operating system, device type and language;
• your IP address, which your browser sends with every request. Google uses it to estimate your country and region, and says Google Analytics doesn't log or store IP addresses;
• two first-party cookies, _ga and _ga_ followed by our property code. One holds a random ID, the other the current visit; each lasts up to 2 years. The ID lets Google Analytics tell a returning browser from a new one.

Because page addresses and titles name the peptide a page is about, Google Analytics sees which peptide pages are read. It never receives your name, your email, anything you type into a form (email, state or peptides) or your sign-up record, and we never send it a user ID.

Our Google Analytics settings. Google signals and ad personalization are off. Google's data-sharing settings are off, and our account isn't linked to Google Ads or any other ad product; Google says that with data sharing off, it uses our Analytics data only to provide, maintain and protect the Analytics service. Automatic tracking of clicks, scrolls, searches, file downloads and form use is off, and so is Google's automatic detection of email addresses, phone numbers and street addresses on a page. City-level location and detailed device data, such as device model and screen resolution, are off. How long the data is kept: see Retention.

Do Not Track and Global Privacy Control. If your browser sends either signal, Google Analytics doesn't load: no Google script, no new cookies, and nothing is sent to Google. Cookies from an earlier visit stay until they expire or you clear them. The rest of the site works exactly the same. You can also block cookies in your browser settings, or install Google's opt-out add-on from tools.google.com/dlpage/gaoptout. Google Analytics' cookies are set for ellumclinic.com only, so its random ID here can't be read on other websites. No company collects information about your activity across different websites when you use Ellum.

Where it's stored and who can see it

Your sign-up is stored in our database in a separate, locked-down area: the website can add a sign-up, but it can't read sign-ups back, and the record of what you consented to can only be added to; the one change we can make is removing your email link and the peptide names when we delete your sign-up.

These service providers handle data for us, only to run Ellum:

Inside Ellum, one role can see sign-up data: Ellum's founder, who runs it, to send email and answer your requests.

We don't sell your information. Selling it would need a separate written permission from you that names the buyer, and signing up never depends on it.

We pass your email, state and peptides to Ellum Clinic or a medical practice licensed in your state only if you tick that box, and we confirm by email before passing them to a specific practice. We aren't paid for passing them on. Once a practice has your details, its own privacy notice covers what you tell it. We don't share your information with pharmacies, peptide sellers, advertisers or researchers.

Ellum Clinic will be a separate company. When it exists, we'll name it here and in our Consumer Health Data Privacy Policy.

If CMS, LLC or Ellum's business is sold, merged or reorganized, or goes through bankruptcy, your information may pass to the new owner as part of that deal, never on its own. The new owner must keep the promises in this policy for the information you gave us, including your withdrawals and unsubscribes, and must get your agreement before using it in a materially different way. Before a deal closes, a possible buyer sees only totals, never your email.

We may disclose information when the law requires it, for example under a valid court order.

Retention and withdrawing consent

How long we keep it. We keep your sign-up only while at least one of your consents is active, and never longer than 24 months after the last email we sent you or the last time you confirmed your sign-up, whichever is later. Sign-ups that are never confirmed are deleted after 30 days. When you withdraw every consent or ask us to delete your data, we delete your sign-up (email, state and peptides) within 45 days. Copies in our database backups are gone within six months.

We keep one thing after deletion: a record of which kinds of box were ticked or withdrawn and when, without your email, your state or the peptides you chose. On its own it can't be linked back to you. We keep it to show that we only ever emailed people who agreed. Our email provider, Resend, keeps its own record of each email it sent you, including your address, for 30 days.

Analytics data. Google Analytics keeps visit-level data, tied to its random ID, for 2 months, then deletes it. Google deletes in a monthly batch, so it can take a few weeks longer. Its standard reports show only totals, such as visits per page or per country; the 2-month limit doesn't apply to those totals. Its two cookies last up to 2 years after your last visit, or less if you or your browser delete them.

Withdrawing consent. You can withdraw any one consent, or all of them:

• use the unsubscribe link in any email (it stops that kind of email, and keeps working for at least 30 days after the email was sent);
• or email hello@ellumclinic.com from the address you signed up with and tell us what to stop.

Withdrawing is free. We stop the emails you withdrew from within 10 business days, and it doesn't affect anything else you've signed up for unless you ask.

Your rights and contact

Wherever you live, you can ask us to:

• confirm whether we hold information about you, and send you a copy;
• tell you which service providers and practices have received it;
• correct it;
• delete it;
• stop any or all emails.

Google Analytics data is tied only to a random ID in your browser, not to your name or email, so we can't find it from your email address. Clearing your cookies starts a new ID, and the old data is deleted after 2 months.

Email hello@ellumclinic.com from the address you signed up with. To protect you, we confirm the request by replying to that address before we act. We answer within 45 days, or tell you within that time if we need up to 45 more days and why. If we turn down a request, you can appeal by replying "appeal"; we answer the appeal within 45 days. If we deny the appeal, you can complain to your state's attorney general. Washington, Nevada and Connecticut residents have specific rights over consumer health data, described in our Consumer Health Data Privacy Policy.

Children. Ellum's sign-ups are for adults 18 and over. We don't knowingly collect information from anyone under 18, and we delete it if we learn we have.

Security. We limit who and what can reach sign-up data, and pages and sign-ups travel over an encrypted (HTTPS) connection. No system is perfectly secure; if a breach affects your information, we'll tell you as the law requires.

Changes. If we change this policy, we post the new version here with a new effective date. A change that affects data you've already given us applies to your data only if you agree to it.

Contact. CMS, LLC · hello@ellumclinic.com · 10940 SW Barnes Rd. #338, Portland, OR 97225