Legal

Privacy Policy

Effective: TBD — V1.0 launch date · Last updated: TBD

Section 1

Introduction

This Privacy Policy describes how Bridgeway Materials LLC(“Bridgeway”, “we”, “us”, or “our”) collects, uses, and shares information when you visit bridgewaymaterials.com(the “Site”) or interact with us through the Site, email, or phone.

We are a U.S. business-to-business merchant wholesaler focused on ferrosilicon. Our Site serves industrial procurement professionals at steel mills, alloy plants, foundries, and similar industrial operations. We do not sell consumer products, do not target individuals under 18, and do not knowingly collect children's data.

Contact for privacy questions: privacy@bridgewaymaterials.com (or alan.ng@bridgewaymaterials.com).

Section 2

Information We Collect

We collect minimal information and only what is necessary to operate as a B2B commercial counterparty.

2.1 Information you provide directly

When you submit our Request a Quote (RFQ) form or contact us via email/phone, we collect:

  • Company name and country/state of operation
  • Contact name and job title
  • Business email address and business phone number
  • Role / business type (e.g., steel mill, alloy plant, foundry, trader)
  • Estimated annual ferrosilicon volume (range only, not exact)
  • Product specification needs and target delivery region
  • Timeline / delivery preferences
  • Any special requirements you choose to include in free-text notes
  • Communications you send us via email, phone, or postal mail

The RFQ form runs on our own Site. When you submit it, our server forwards the information to HubSpot, Inc., where the inquiry is stored and where we work it. Your browser does not contact HubSpot directly, and HubSpot sets no cookies on your device.

2.2 Information collected automatically

When you visit the Site, our hosting infrastructure (Cloudflare) automatically collects: IP address, browser type and version, operating system, referring URL, pages visited with approximate timestamps, and approximate geographic region (city/country level — no precise location).

We use two analytics services. Cloudflare Web Analytics is privacy-first: no cookies, no cross-site tracking, no fingerprinting. Google Analytics 4 (GA4) uses first-party cookies to measure how visitors reach and use the Site; we have disabled Google Signals and advertising features, so GA4 data is not used for cross-site tracking, ad personalization, or advertising.

We do not forward your IP address to HubSpot with your inquiry, and we do not pass HubSpot any browser tracking identifier.

2.3 Cookies and similar technologies

Strictly necessary cookies, used only for site operation and security:

  • Cloudflare security cookies (__cf_bm, cf_clearance) — bot management and DDoS protection
  • bw_consent — records whether you accepted or declined analytics cookies, so we do not ask again; expires after 12 months

Analytics cookies, used to measure Site traffic and usage:

  • Google Analytics cookies (_ga, _ga_*) — first-party; distinguish visitors and measure how the Site is used; expire up to 2 years; analytics only, not advertising

If you are visiting from the European Economic Area, the United Kingdom, or Switzerland, Google Analytics is not loaded and sets no cookies unless you accept it. We ask once, in a banner at the foot of the page, and remember your answer. Declining is a single click and leaves the Site fully usable. You can change your answer at any time using the "Cookie preferences" link in the footer.

Elsewhere — including the United States, where we are based — analytics runs by default, which is permitted under applicable law. You can still decline at any time via the same footer link.

We do NOT use advertising cookies, cross-site tracking cookies, third-party social trackers (Facebook Pixel, LinkedIn Insight, etc.), marketing automation cookies, or persistent advertising identifiers. Our RFQ form sets no cookies of its own, and because submissions are forwarded from our server rather than from your browser, HubSpot cannot set cookies on your device through it.

2.4 Information we do NOT collect

To be explicit: no government IDs, no financial account numbers or banking credentials, no health or biometric data, no children's data, no precise geolocation, no audio or video recordings.

Section 3

How We Use Information

We use the information we collect to:

  • Respond to your inquiry — typically within 24 hours of submission
  • Communicate with you about potential purchases, orders, shipping documentation, or logistics
  • Operate the Site, prevent abuse, secure against attacks, and maintain availability
  • Improve our services through aggregate analytics
  • Comply with legal obligations — U.S. customs record retention (19 USC § 1508 requires 5-year retention), tax reporting, and other applicable law
  • Establish and defend legal claims when necessary

We do NOT use your information for targeted advertising, sale/rental/trade to third parties, profiling with legal effects, or marketing communications unless you specifically opt in (we do not currently send marketing emails).

Section 4

How We Share Information

We share information only in the following limited circumstances:

4.1 Service providers (limited, contractual)

We use a small number of vetted service providers, each bound by contract and limited to the specific service:

  • Cloudflare, Inc. — hosting, CDN, security, Turnstile, D1 database, analytics
  • HubSpot, Inc. — storage of RFQ inquiries submitted through our contact form, and our record of the correspondence that follows. Inquiries reach HubSpot from our server, not from your browser
  • Google LLC — Google Analytics 4, for Site traffic measurement; configured with advertising features and Google Signals disabled
  • Resend — transactional email delivery
  • Zoho Corporation — email hosting for @bridgewaymaterials.com addresses

These providers process information solely to provide their services to us — they do not use information for their own purposes.

4.2 Legal compliance

We may disclose information when required by law: response to subpoena or court order, U.S. Customs and Border Protection audits, IRS tax compliance reviews, or law enforcement investigations.

4.3 Business transfers

If Bridgeway is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction, subject to continued protections of this policy.

4.4 With your consent

We may share information with your explicit consent for specific purposes you authorize.

4.5 We do NOT

  • Sell personal information
  • Share personal information with advertising networks, data brokers, or marketing firms
  • Make personal information available to other Bridgeway customers
  • Disclose your inquiry to competitors

Section 5

International Data Transfers

Our infrastructure (Cloudflare global edge network, HubSpot, Resend, Zoho) operates worldwide. RFQ submissions are stored by HubSpot in the United States. When you visit our Site or contact us from outside the United States, your information may be processed in the United States or other countries where our service providers operate.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, transfer to the United States is governed by the EU-U.S. Data Privacy Framework and applicable Standard Contractual Clauses where appropriate. You may contact us for further information.

Section 6

Data Retention

We retain information only as long as necessary for the purposes described:

  • RFQ inquiries that do not progress to a transaction: 2 years from submission, then deleted
  • Active customer relationship records (transactions, shipping, payment): 5 years from each transaction (required by 19 USC § 1508)
  • Communications: 5 years from last contact
  • Cloudflare Web Analytics (aggregate, non-identifying): per Cloudflare's standard (typically 6 months)
  • Google Analytics (GA4): per our configured retention setting (up to 14 months), after which user-level data is deleted
  • Backup copies: per routine backup rotation, then permanently deleted

RFQ inquiries are held in HubSpot for the periods above. When we delete an inquiry, we delete it from HubSpot as well as from our own records.

You may request deletion of your information earlier where we do not have a legal obligation to retain — see §8 below.

Section 7

Data Security

We use reasonable technical and organizational measures to protect information: HTTPS/TLS encryption for all Site traffic (Cloudflare-managed certificates), encrypted storage at rest for inquiry records held with HubSpot, access controls limiting internal access to authorized personnel only, automated bot filtering on the RFQ form plus Cloudflare WAF and DDoS protection, and regular security review of service providers.

No system is completely secure. If we become aware of a data breach affecting your information, we will notify you and applicable authorities as required by law.

Section 8

Your Rights

Depending on your location, you may have the following rights regarding your personal information:

8.1 All visitors

  • Access: request a copy of personal information we hold about you
  • Correction: request that we correct inaccurate information
  • Deletion: request that we delete information we are not legally required to retain
  • Opt-out: we do not currently send marketing email; if we begin in the future, you may opt out
  • Withdraw consent: if you accepted analytics cookies, you can withdraw that at any time — as easily as you gave it — via the "Cookie preferences" link in the footer

8.2 California residents (CCPA / CPRA)

  • Right to know what personal information we collect, use, and share
  • Right to delete personal information we are not legally required to retain
  • Right to correct inaccurate personal information
  • Right to opt out of "sale" or "sharing" for cross-context behavioral advertising (we do not sell or share for advertising)
  • Right to limit use of sensitive personal information (we do not collect sensitive PI as defined by CCPA)
  • Right to non-discrimination for exercising privacy rights

To exercise these rights, contact privacy@bridgewaymaterials.com. We will verify your identity before processing requests and respond within 45 days (extendable to 90 days if necessary).

8.3 European Economic Area / UK residents (GDPR)

  • Access, rectification, erasure (same as above)
  • Restriction of processing in certain circumstances
  • Data portability for information you provided to us
  • Object to processing based on our legitimate interests
  • Withdraw consent where we relied on consent
  • Lodge a complaint with your local data protection authority

Our legal basis for processing under GDPR: Contract (Art. 6(1)(b)) for processing your RFQ; Legitimate interests (Art. 6(1)(f)) for operating the Site, preventing abuse, defending legal claims, improving service quality; Legal obligation (Art. 6(1)(c)) for tax and customs record retention.

8.4 Canada (PIPEDA) and Mexico (LFPDPPP)

If you are in Canada or Mexico, your rights under applicable national privacy law (PIPEDA / LFPDPPP) are honored. Contact privacy@bridgewaymaterials.com.

Section 9

Children's Privacy

The Site is intended for business-to-business industrial procurement professionals. We do not knowingly collect personal information from anyone under the age of 18. If we learn we have collected information from a person under 18, we will delete it.

Section 10

“Do Not Track” Signals

Our Site does not respond to "Do Not Track" browser signals at this time because we do not engage in cross-site or cross-context tracking, we do not sell or share personal information for advertising, and our analytics (Cloudflare Web Analytics and Google Analytics 4 — the latter with Google Signals and advertising features disabled) do not track users across sites.

Section 12

Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the latest revision. Material changes will be announced on the Site at least 30 days before taking effect. Your continued use of the Site after the effective date constitutes acceptance of the revised policy.

Section 13

Governing Law

This Privacy Policy is governed by the laws of the State of Illinois, United States of America, without regard to conflict-of-laws principles. Disputes arising under this Policy shall be resolved as set forth in our applicable customer agreements.

Section 14

Contact Us

For questions, requests, or concerns about this Privacy Policy or our data practices:

Bridgeway Materials LLC
Attention: Privacy
Chicago, Illinois, USA

Email: privacy@bridgewaymaterials.com (or alan.ng@bridgewaymaterials.com)
Phone: +1 (773) 500-3788

We will respond to privacy inquiries within a reasonable timeframe, typically within 5 business days.