There are NON-refrigerated ones?!
Actually, yogurt is supposed to be safe to leave out. I wouldn't do it, though. I leave butter and ghee out. (Butter bell for butter, I put a little salt in the water since I use unsalted butter - the salt controls various nasty growth) And ghee in the jar in which it was bought. (Why Whole Foods refrigerates one brand of ghee - but not others - is beyond me...)
I would say most probiotic supplements I see sold in stores around me are NOT refrigerated. Certain types of probiotics can survive unrefrigerated, but all types survive for longer and in greater numbers if refrigerated. Whole Foods is one of the few stores near me that actually sells refrigerated probiotics.