Privacy Policy

1. Overview

1.1 Who We Are

Wholesale Hub ("Wholesale Hub," "we," "us," or "our") is a Delaware corporation operated from Florida. We provide a private beta B2B wholesale marketplace that connects consumer packaged goods buyers and suppliers and offers related platform services, including account onboarding, catalog management, ordering, payment facilitation, shipping coordination, claims administration, analytics, and related support (collectively, the "Platform").

1.2 Scope of This Privacy Policy

This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when you:

• •visit our website or other online services;
• •apply for or maintain a Buyer or Supplier account;
• •place, receive, fulfill, manage, or dispute Orders;
• •communicate with us or with other users through the Platform;
• •use related payment, shipping, claims, or support features; or
• •otherwise interact with us online or offline in connection with the Platform.

This Privacy Policy applies to personal information collected in both online and offline contexts. It does not apply to third-party websites, services, or platforms that we do not control, even if they are linked from or integrated with the Platform.

1.3 Business-to-Business Context

Wholesale Hub is a business-to-business service. Even so, we may collect and process personal information about identifiable individuals, including employees, owners, officers, contractors, and other representatives of Buyers and Suppliers. References in this Policy to "personal information" mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or identifiable individual.

1.4 Related Terms

Your use of the Platform is also subject to our Terms of Service and any other applicable policies, notices, or supplemental terms we provide.

1.5 Changes to This Privacy Policy

We may update this Privacy Policy from time to time, especially as our private beta evolves and our features change. If we make material changes, we will update the "Last Updated" date and provide additional notice where required by law. Your continued use of the Platform after an updated Privacy Policy becomes effective means you acknowledge the updated Policy.

2. Personal Information We Collect

2.1 Information You Provide Directly

We collect personal information you provide to us directly, including when you apply for access, create an account, complete a profile, place or fulfill an Order, submit a Claim, contact support, or otherwise use the Platform. This may include:

• •account and contact information, such as your name, business email address, phone number, job title, company name, business address, and login credentials;
• •business profile information, such as company type, tax status, resale documentation, licenses, and information about your business operations;
• •verification and compliance information, such as tax identification information, beneficial ownership information, government-issued identification or similar verification records, and other information reasonably requested for onboarding, fraud prevention, payment setup, sanctions screening, or legal compliance;
• •payment and payout information, such as billing contact details, bank account information, payout instructions, and limited payment-related metadata received from payment processors;
• •Order and transaction information, such as the Products you buy or sell, quantities, pricing, shipping preferences, delivery instructions, invoices, purchase records, payment status, returns, and refunds;
• •shipping and logistics information, such as sender and recipient contact details, shipping addresses, carton or pallet details, dimensions, weights, tracking references, delivery notes, and proof of delivery or shipment status;
• •Claims and dispute materials, such as photographs, videos, lot or expiration data, invoices, delivery records, notes, and other supporting evidence you submit through our claims system;
• •communications, such as messages you send through the Platform, support requests, survey responses, and other correspondence with us or other users; and
• •marketing and preference information, such as your email preferences, event signups, survey responses, and feedback.

2.2 Information Collected Automatically

When you access or use the Platform, we and our service providers may automatically collect certain information from your browser, device, or activity on the Platform. This may include:

• •device and network information, such as IP address, browser type, device type, operating system, device identifiers, language, time zone, and referral URLs;
• •activity and usage information, such as pages viewed, links clicked, session duration, search queries, cart activity, account actions, timestamps, errors, crash logs, and similar interaction data;
• •approximate location information derived from IP address, shipping information, or other network data;
• •cookie, pixel, local storage, SDK, and similar identifier data used for authentication, preferences, analytics, fraud prevention, and performance; and
• •security and fraud signals, such as login events, authentication attempts, unusual access patterns, device risk indicators, and related activity.

2.3 Information We Receive From Third Parties

We may receive personal information from other sources, including:

• •payment processors and financial service providers, such as Stripe, which may provide transaction status, payout status, verification, risk, dispute, and account-related information;
• •shipping, logistics, and tracking providers, such as label providers, carriers, freight brokers, and tracking partners, which may provide rate, label, shipment, tracking, delivery, and exception data;
• •identity, fraud, sanctions, or business verification vendors;
• •Buyers or Suppliers participating in a transaction with you;
• •public sources, commercial data providers, and business databases that help us confirm business identity, contact details, licensing status, or company information; and
• •service providers that help us operate support, communications, analytics, hosting, security, and AI-assisted features.

2.4 Shared Catalog and AI-Related Information

The Platform may include a shared catalog and AI-assisted features. In that context, we may collect and process:

• •supplier-submitted product and offer data;
• •product images, descriptions, specifications, pricing, weights, dimensions, and compliance-related fields;
• •prompts, search inputs, corrections, feedback, or other user interactions with AI-assisted tools;
• •third-party product data or enrichment data; and
• •outputs generated or assisted by AI tools, recommendation systems, fraud detection systems, search ranking systems, or operational workflows.

Please do not include unnecessary personal information in public-facing catalog fields, product listings, or prompts submitted to shared AI features.

3. How We Use Personal Information

3.1 To Provide and Operate the Platform

We use personal information to operate the Platform, create and manage accounts, authenticate users, maintain user sessions, display relevant content, enable ordering workflows, manage Supplier Offers, and support Buyer and Supplier interactions.

3.2 To Review Applications and Verify Businesses

We use personal information to evaluate applications, verify that users are legitimate businesses, confirm the authority of business representatives, detect fraud, screen for prohibited activity, and satisfy payment processor, shipping, tax, sanctions, or other legal and compliance requirements.

3.3 To Process Orders, Payments, and Payouts

We use personal information to facilitate Orders, collect and reconcile payments, distribute payouts, support refunds, manage payment disputes and chargebacks, provide receipts and transaction records, and administer Order-related workflows.

3.4 To Coordinate Shipping and Fulfillment

We use personal information to obtain rates, purchase shipping labels on behalf of Suppliers, book freight shipments, generate shipment records, provide tracking updates, coordinate delivery, and reconcile shipping-related charges and adjustments.

3.5 To Manage Claims, Returns, and Disputes

We use personal information to investigate, evaluate, and resolve Claims and related disputes, administer credits or refunds, assess evidence, communicate with relevant parties, and maintain records for compliance, audit, and operational purposes.

3.6 To Communicate With You

We use personal information to send transactional or service messages, security alerts, support responses, onboarding updates, payout notifications, shipping updates, claims notices, policy changes, and other communications related to your use of the Platform. Where permitted by law, we may also send business marketing or product update communications, subject to your choices.

3.7 To Improve, Analyze, and Develop the Platform

We use personal information to understand how users interact with the Platform, troubleshoot bugs, monitor performance, improve usability, develop features, perform analytics, measure engagement, and support internal research and product development. This may include using business, transaction, catalog, and interaction data to improve recommendations, search, risk review, or AI-assisted features.

3.8 To Maintain Security and Prevent Misuse

We use personal information to detect, investigate, prevent, and respond to fraud, abuse, security incidents, suspicious transactions, policy violations, money laundering concerns, sanctions risks, unauthorized access, and other harmful or unlawful conduct.

3.9 To Comply With Law and Enforce Our Rights

We use personal information to comply with applicable law, tax, accounting, reporting, subpoena, court order, regulatory inquiry, or lawful governmental request, and to establish, exercise, or defend legal claims and enforce our agreements and policies.

3.10 For Corporate and Business Operations

We may use personal information in connection with audits, financing, insurance, vendor management, corporate governance, business continuity, recordkeeping, and actual or proposed mergers, acquisitions, financings, reorganizations, or asset sales.

4. How We Disclose Personal Information

4.1 With Buyers and Suppliers Involved in Transactions

When you participate in a transaction through the Platform, we disclose personal information as necessary to enable the transaction and related support. For example:

• •Buyers may receive Supplier business and shipping-related contact information, product and Offer information, and Order status information;
• •Suppliers may receive Buyer business and shipping-related contact information, Order details, payment status information needed to fulfill Orders, and Claim-related materials; and
• •both sides may receive information necessary to communicate about an Order, delivery issue, refund, or Claim.

Once a counterparty receives information necessary for a transaction, that counterparty may independently control and retain its copy subject to its own privacy practices and legal obligations.

4.2 With Your Organization and Authorized Representatives

If your account is tied to a business entity, the business and its authorized representatives may be able to access, manage, update, or export information associated with that business account, including profile details, Order history, messages, claims records, and settings.

4.3 With Service Providers

We disclose personal information to vendors and service providers that perform services on our behalf, such as hosting, cloud infrastructure, data storage, authentication, email delivery, customer support, analytics, fraud prevention, business verification, AI-assisted tooling, and other operational services. These providers are authorized to use personal information only as necessary to provide services to us or as otherwise permitted by law.

4.4 With Payment Processors and Financial Partners

We disclose personal information to payment processors, payment networks, banks, and related financial partners to process payments, enable payouts, support verification, manage disputes, comply with financial regulations, and prevent fraud.

4.5 With Shipping, Logistics, and Tracking Partners

We disclose personal information to label providers, carriers, freight brokers, shipment booking partners, tracking providers, and related logistics vendors to obtain rates, purchase labels, book shipments, provide delivery updates, support claims, and reconcile shipping costs.

4.6 With Professional Advisors and Authorities

We may disclose personal information to auditors, insurers, lawyers, accountants, financing sources, regulators, law enforcement, courts, or other governmental authorities when reasonably necessary to comply with law, respond to legal process, protect rights or safety, investigate wrongdoing, or support corporate transactions.

4.7 In Corporate Transactions

We may disclose or transfer personal information as part of an actual or proposed merger, acquisition, asset sale, financing, reorganization, bankruptcy, or similar transaction involving all or part of our business, subject to customary confidentiality and diligence requirements.

4.8 With Your Direction or Consent

We may disclose personal information when you direct us to do so, consent to the disclosure, or intentionally use integrations or workflows that involve disclosure to third parties.

4.9 Aggregated and De-Identified Information

We may create and use aggregated, anonymized, or de-identified data that no longer reasonably identifies an individual. We may use and disclose such information for analytics, benchmarking, market insights, operational improvement, and other lawful purposes. We will not attempt to reidentify de-identified information except as permitted by law.

5. Cookies and Similar Technologies

5.1 Technologies We Use

We and our service providers may use cookies, pixels, local storage, scripts, SDKs, web beacons, and similar technologies on our website and related services. These technologies help us:

• •keep users signed in and secure accounts;
• •remember preferences and settings;
• •understand traffic, performance, and user behavior;
• •prevent fraud and abuse;
• •troubleshoot and improve the Platform; and
• •support communications, measurement, and limited business marketing.

5.2 Your Choices

You may be able to control certain cookies or similar technologies through your browser settings, device settings, or any cookie management tools we make available. Blocking some cookies may affect Platform functionality, performance, or security features.

5.3 Email and Similar Communications

Some emails may include technologies that help us understand whether a message was delivered, opened, or engaged with. We use this information to improve communications, support deliverability, and measure product communications. You can opt out of promotional emails at any time using the unsubscribe link in those emails, but you may still receive transactional or service-related messages.

6. Payments, Shipping, and Other Third-Party Services

6.1 Payment Processing

Payments on the Platform are processed by third-party payment providers, including Stripe and Stripe Connect. When you make a payment, receive a payout, or complete onboarding related to payment services, your information may also be collected, used, and disclosed by those providers under their own terms and privacy practices. We generally do not store full payment card numbers. We may receive limited information from payment processors, such as payment status, tokenized payment information, payout status, dispute information, and verification results.

6.2 Shipping and Logistics

When we coordinate shipping as part of the Platform, we disclose information needed to rate, label, book, track, and support shipments. This may include names, business contact information, delivery addresses, parcel or freight details, dimensions, weights, item counts, declared contents, and related shipment information. Providers involved in these workflows may include Shippo, carriers, freight brokers, and tracking or logistics partners.

6.3 Third-Party Services and Integrations

The Platform may rely on third-party services for hosting, communications, analytics, support, AI assistance, fraud prevention, security, and other functions. Information disclosed to those providers is subject to their own privacy practices to the extent they act independently, and to our instructions where they act as our service providers.

7. AI Features, Shared Catalog, and De-Identified Data

7.1 AI-Assisted Features

We may use AI, machine learning, rules-based systems, or similar tools to support product catalog enrichment, search, recommendations, fraud review, workflow automation, support, analytics, and internal operations. These tools may use account, transaction, shipping, catalog, and interaction data as inputs.

7.2 Accuracy and User Responsibility

AI-generated or AI-enriched content may be incomplete or inaccurate. Suppliers remain responsible for verifying product and Offer information associated with their listings. Users should independently review important content before relying on it.

7.3 Use of Data for Improvement

We may use data submitted through the Platform to test, evaluate, and improve our services and internal models. Where practicable and appropriate, we use aggregated, de-identified, or redacted data for these activities. We do not need additional consent to use de-identified information for lawful business purposes.

8. Data Retention

8.1 Retention Periods

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• •maintain active accounts and business relationships;
• •complete transactions and provide requested services;
• •support shipping, claims, refunds, chargebacks, and dispute resolution;
• •comply with tax, accounting, payment, sanctions, and legal obligations;
• •prevent fraud and maintain security;
• •enforce agreements and protect our rights; and
• •support backup, disaster recovery, audits, and business continuity.

8.2 Retention Criteria

The length of time we retain personal information depends on the nature of the information, the sensitivity of the information, the purpose for which it was collected, the risk of harm from unauthorized use or disclosure, whether the information is needed for current or anticipated disputes or compliance obligations, and whether we can achieve the same purpose by other means.

8.3 Deletion and Residual Copies

When personal information is no longer reasonably necessary, we may delete it, aggregate it, or de-identify it. Residual copies may remain for a limited period in backups, logs, archives, or disaster recovery systems.

9. Data Security

9.1 Our Security Practices

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards are designed with the nature of our business, the sensitivity of the information, and the risks involved in mind.

9.2 No Absolute Guarantee

No method of transmission over the internet, no software, and no storage system is completely secure. As a result, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials, using strong passwords, restricting access to authorized users, and notifying us promptly if you suspect unauthorized access or misuse.

9.3 Incident Response

If we become aware of a security incident affecting personal information, we will investigate and take steps we consider appropriate under the circumstances, including providing notice where required by law.

10. Your Privacy Choices and Rights

10.1 Access, Correction, and Account Updates

You may review and update certain account information by logging into your account or contacting us. We encourage users to keep business and contact information current so that Orders, payouts, shipping, and communications are accurate.

10.2 Communication Preferences

You may opt out of promotional or marketing emails by using the unsubscribe link in those messages or by contacting us. Even if you opt out of promotional communications, we may still send service-related messages, including notices about Orders, payments, payouts, account activity, claims, policy changes, and security events.

10.3 Cookie and Browser Controls

You may control certain cookies and tracking technologies through browser settings, device settings, or any cookie controls we make available. Blocking certain technologies may limit Platform functionality.

10.4 Privacy Rights Under Applicable Law

Depending on where you live and the nature of our relationship with you, you may have the right to request that we:

• •confirm whether we process your personal information;
• •provide access to or a copy of your personal information;
• •correct inaccurate personal information;
• •delete personal information, subject to exceptions;
• •provide a portable copy of certain personal information;
• •disclose categories of personal information collected, sources, purposes, and categories of recipients;
• •allow you to opt out of certain disclosures or uses that may be characterized under applicable law as a sale, sharing, targeted advertising, or certain profiling; or
• •limit certain uses or disclosures of sensitive personal information, where applicable.

10.5 How to Exercise Rights

To submit a privacy request, contact us at privacy@wholesalehub.ai with enough information for us to identify you and understand the nature of your request. We may ask for additional information to verify your identity or authority before responding. Where allowed by law, we may deny or limit requests that cannot be verified, that are manifestly unfounded or excessive, that would adversely affect the rights of others, or where an exception applies.

10.6 Authorized Agents

Where permitted by law, you may designate an authorized agent to submit a request on your behalf. We may require proof of the agent's authority and may also ask you to verify your identity directly.

10.7 Appeals

If we deny your request in whole or in part and you believe the denial was incorrect, you may contact us to appeal the decision where applicable law provides an appeal right. We will review the appeal in accordance with applicable law.

10.8 Non-Discrimination

We will not discriminate against you for exercising applicable privacy rights, except as permitted by law. For example, some services or features may require certain information to function, and we may be unable to provide those services if you ask us to delete or stop using information that is necessary to operate them.

10.9 Information Controlled by Other Users

If your request relates to information independently controlled by a Buyer, Supplier, payment processor, carrier, or other third party, we may direct you to that party, because their privacy practices and legal obligations may govern the information they hold.

11. U.S. State Privacy Notice

11.1 Categories of Personal Information We Collect

During the 12 months preceding the Last Updated date of this Privacy Policy, we may have collected the following categories of personal information, depending on how you interact with the Platform:

• •identifiers and contact information, such as name, email address, phone number, IP address, account identifiers, and business contact details;
• •commercial information, such as Order history, Product interests, cart activity, purchasing records, claims records, and transaction details;
• •financial and payment-related information, such as payout instructions, bank account details, payment metadata, billing information, and dispute or chargeback information;
• •internet or other electronic network activity information, such as browsing activity, device and browser data, usage logs, interactions with the Platform, and analytics data;
• •geolocation information, such as approximate location derived from IP address and shipping or delivery location information;
• •professional or employment-related information, such as company name, role, title, business category, licenses, resale documentation, and business verification information;
• •user-generated content and communications, such as messages, support requests, survey responses, uploaded documents, and Claim materials;
• •inferences drawn from other personal information, such as general purchasing preferences, operational patterns, fraud-risk indicators, and product or feature interests; and
• •sensitive personal information, where relevant to our services, such as account credentials, financial account information, tax or government identifiers, and other verification information.

11.2 Sources of Personal Information

We collect the categories above from:

• •you directly;
• •your business or its authorized representatives;
• •other Buyers or Suppliers involved in transactions with you;
• •payment processors, carriers, freight providers, tracking providers, and verification vendors;
• •public records, commercial data providers, and business databases; and
• •cookies, device signals, logs, and other automatic collection technologies.

11.3 Business and Commercial Purposes

We collect and use the categories above for the purposes described in Section 3, including account administration, business verification, Order processing, payment facilitation, payout administration, shipping coordination, claims resolution, support, analytics, security, fraud prevention, legal compliance, internal research, product improvement, and communications.

11.4 Categories of Recipients

We may disclose the categories above to:

• •Buyers and Suppliers involved in transactions;
• •service providers and contractors that support hosting, authentication, support, communications, analytics, security, AI, and operations;
• •payment processors, banks, and other financial partners;
• •shipping, freight, tracking, and logistics providers;
• •advisors, auditors, insurers, and financing or transaction counterparties;
• •regulators, courts, law enforcement, and other governmental authorities when required or appropriate; and
• •other parties with your consent or at your direction.

11.5 Sensitive Personal Information

To the extent we collect sensitive personal information, we generally use it only for purposes reasonably necessary to provide the Platform, authenticate users, process payments and payouts, verify businesses and representatives, prevent fraud, comply with law, maintain security, and perform other purposes permitted by applicable law. We do not use sensitive personal information to infer characteristics about individuals except as reasonably necessary for fraud prevention, risk management, or similar operational purposes permitted by law.

11.6 Sale, Sharing, and Targeted Advertising

Wholesale Hub does not currently sell personal information for monetary compensation, and we do not rent personal information. Like many online services, however, we may use cookies or similar technologies through analytics, measurement, or marketing-related providers. Depending on applicable law and how those tools are configured, certain disclosures related to those technologies may be treated as "sale," "sharing," or "targeted advertising." Where applicable, you may exercise opt-out rights by contacting us at privacy@wholesalehub.ai and using any privacy or cookie settings we make available.

We do not knowingly sell or share the personal information of minors under sixteen (16) years of age.

11.7 Retention

We retain each category of personal information for as long as reasonably necessary for the purposes described in this Privacy Policy and in light of our business needs, legal obligations, security requirements, dispute resolution needs, and operational realities. For more information, see Section 8.

11.8 State Law Requests

Residents of certain U.S. states may have rights to access, correct, delete, or obtain a copy of personal information, or to opt out of certain uses or disclosures. The process for making those requests is described in Section 10. If required by applicable law, we will respond within the required timeframe and explain any basis for denying a request.

12. International Users

12.1 U.S. Processing

Wholesale Hub is based in the United States, and our service providers may process personal information in the United States or other jurisdictions where they operate. If you access the Platform from outside the United States, you understand that your personal information may be transferred to, stored in, and processed in countries that may have different data protection laws than your jurisdiction.

12.2 Business Use Across Borders

Because the Platform is a B2B marketplace, international access may also involve disclosure of business contact, shipping, and transaction information across borders where necessary to complete transactions, process payments, book shipments, prevent fraud, or comply with law.

13. Children's Privacy

13.1 Not Directed to Children

The Platform is intended only for businesses and their authorized representatives and is not directed to children. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us at privacy@wholesalehub.ai so we can review and take appropriate action.

14. Third-Party Links and Services

14.1 Third-Party Privacy Practices

The Platform may contain links to third-party websites, payment pages, carrier tools, or other services. This Privacy Policy does not apply to third-party services that we do not control. We encourage you to review the privacy policies of those third parties before providing information to them.

15. Changes to This Privacy Policy

15.1 Updates

We may revise this Privacy Policy from time to time to reflect changes in our products, legal requirements, service providers, business practices, or private beta operations. When we do, we will update the "Last Updated" date and, where required, provide additional notice.

16. Contact Us

16.1 Privacy Contact

If you have questions about this Privacy Policy or would like to submit a privacy request, contact us at:

Wholesale Hub
Attn: Privacy
privacy@wholesalehub.ai

16.2 Additional Information

If we need more information to verify or process your request, we may contact you using the information associated with your account or request.