Privacy Policy

1. About Club12.us

Club12.us is a fictitious name (DBA) of Hermitage Investment Management LLC, a Pennsylvania limited liability company.

Club12 operates a commercial platform and network designed to connect brands, retailers, distributors, and other business participants and to support product discovery, market development, retail placement, product launches, and related commercial activities.

Club12 is primarily a business-to-business service. Most of the information we collect and process relates to businesses, products, commercial activities, and business relationships.

2. Information We Collect

Business Information

In connection with Club12 services, we may collect information about brands, retailers, distributors, and other participating businesses.

This may include:

• company name, address, website, and business contact details;
• company and business profile information;
• product information and product documentation;
• pricing and commercial information;
• distribution and market information;
• retailer and store information;
• certifications, licenses, and related documentation;
• insurance documentation;
• product specifications and supporting materials;
• sales, placement, and product performance information;
• information provided through applications, assessments, forms, reports, meetings, and communications; and
• other business information reasonably necessary to evaluate, provide, or administer Club12 services.

Some documents may include validity or expiration dates. Club12 may record and monitor those dates where necessary to administer its services, verify documentation, or request updated documentation.

Business Contact Information

When a business interacts with Club12, we may also collect information about the individuals representing that business, such as:

• name and surname;
• business email address;
• business telephone number;
• job title or role;
• company affiliation; and
• information contained in business communications with Club12.

Where business contact information identifies an individual, Club12 uses that information as reasonably necessary to communicate with the business, provide our services, manage the business relationship, and carry out the applicable transaction, program, or commercial activity.

Website and Technical Information

When you use our website or online services, we may automatically receive limited technical information, such as IP address, browser or device information, website activity, and similar technical data.

We may use this information for website operation, security, troubleshooting, analytics, and improvement of our services.

3. How We Use Information

Club12 collects and uses information as reasonably necessary to provide its services, fulfill contractual and business relationships, operate the Club12 platform, communicate with participants, and carry out legitimate business purposes.

This may include using information to:

• process brand, retailer, distributor, or other business applications;
• communicate with businesses and their representatives;
• provide requested services;
• conduct brand, product, retailer, or market assessments;
• evaluate brands, products, retailers, and commercial opportunities;
• prepare reports, presentations, assessments, and product offers;
• connect brands with retailers, distributors, and other relevant business participants;
• support product discovery, placement, testing, and launch programs;
• manage commercial relationships and Club12 programs;
• verify business information and documentation;
• monitor document, certification, insurance, or other validity dates;
• request updated documentation where necessary;
• process payments and administer transactions;
• collect and analyze sales, placement, and product performance information;
• provide operational and service-related communications;
• maintain records relating to our services and business relationships;
• maintain, protect, and improve the Club12 platform and services;
• prevent fraud, misuse, or security incidents; and
• comply with applicable legal and regulatory requirements.

Club12 does not collect information simply for the purpose of collecting it.

4. How We Share Information

Club12 does not sell personal information.

We may share business information and relevant business contact information where reasonably necessary to provide our services or facilitate a business opportunity.

Depending on the applicable service or program, information may be shared with:

• participating brands;
• retailers;
• distributors;
• other relevant business participants;
• service providers supporting Club12 operations;
• payment processors;
• hosting, technology, communications, analytics, database, and automation providers;
• professional advisers where reasonably necessary; and
• governmental, regulatory, or legal authorities where disclosure is required by law.

Information shared with another business participant will generally be limited to information reasonably relevant to the applicable service, program, transaction, or commercial opportunity.

For example, information submitted by a brand may be used to prepare assessments, product presentations, retailer offers, or other materials used to evaluate or facilitate potential retail placement or commercial opportunities.

5. Business Documents and Confidential Information

Club12 may receive business documents and commercially sensitive information in connection with its services.

This may include product documentation, pricing, certifications, insurance documentation, distribution information, market information, product specifications, business plans, and other materials.

Where information is identified as confidential or is reasonably understood to be confidential based on its nature and the circumstances in which it was provided, Club12 will treat it accordingly and will not intentionally make it publicly available unless authorized or required by law.

Information may nevertheless be used or shared to the extent reasonably necessary to perform the service for which it was provided or to facilitate an applicable commercial opportunity.

6. Payments

Club12 may use third-party payment providers to process payments.

When payment information is entered directly through a third-party payment provider, Club12 does not need to receive or store complete payment-card details.

Payment providers process payment information according to their own terms, privacy policies, and security practices.

7. Cookies and Website Technologies

Club12 may use cookies and similar technologies that are reasonably necessary for website functionality, security, analytics, and improving the operation of our website and services.

Third-party services integrated with the Club12 website may also collect limited technical information according to their own privacy policies.

Where consent for non-essential cookies or similar technologies is required by applicable law, Club12 will request such consent.

8. How Long We Keep Information

Club12 retains information for as long as reasonably necessary for the purposes for which it was collected.

This may include the time necessary to:

• provide and administer Club12 services;
• maintain business and transaction records;
• manage ongoing or previous business relationships;
• maintain records of assessments, programs, and commercial activities;
• resolve disputes;
• protect Club12's legal and business interests; and
• comply with applicable legal, accounting, tax, or regulatory requirements.

Different types of information may be retained for different periods.

When information is no longer reasonably required, Club12 may delete, anonymize, or securely dispose of it.

9. Data Security

Club12 uses reasonable administrative, organizational, and technical measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure.

Access to information may be limited to Club12 personnel, contractors, and service providers who reasonably require access to perform their functions.

No electronic or online system can guarantee absolute security. However, Club12 takes reasonable precautions appropriate to the nature of the information it handles.

10. Your Choices and Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding personal information relating to you.

Where applicable, these may include the right to request access to, correction of, or deletion of certain personal information, or to object to or restrict certain uses of that information.

You may also contact us to:

• correct inaccurate business contact information;
• update your contact details;
• ask questions about information associated with you; or
• request that we stop sending non-essential marketing communications.

Certain information may need to be retained where reasonably necessary to perform an agreement, maintain business or transaction records, protect legal rights, or comply with applicable law.

To submit a privacy-related request, contact us at hello@club12.us.

We may take reasonable steps to verify the identity or authority of a person making a request.

11. Service Providers and Third-Party Services

Club12 uses third-party providers to operate and support its business.

These may include providers of website hosting, cloud services, email and communications, payment processing, scheduling, analytics, databases, automation, document management, and other business technologies.

These providers may process information on our behalf or as necessary to provide their respective services.

Third-party websites or services may have their own privacy policies and practices. Club12 is not responsible for the independent privacy practices of third parties.

12. International Processing

Club12 may work with brands, retailers, distributors, service providers, and other business participants located in different countries.

As a result, information may be accessed, processed, or stored outside the state or country in which it was originally provided.

Where applicable law requires specific protections for such transfers or processing, Club12 will take reasonable steps to comply with those requirements.

13. Children

Club12 is a business-to-business service and is not intended for children.

Club12 does not knowingly collect personal information from children through its business platform or services.

14. Changes to This Privacy Policy

Club12 may update this Privacy Policy from time to time to reflect changes in our services, business practices, technology, or applicable legal requirements.

The current version will be published on the Club12.us website with its effective date.

15. Contact Us

Questions about this Privacy Policy or Club12's handling of information may be sent to:

Club12.us
a fictitious name (DBA) of
Hermitage Investment Management LLC
Pennsylvania, United States

Email: hello@club12.us
Website: Club12.us