Privacy Policy

Last updated: May 2, 2026 · Effective date: May 2, 2026

PROJET Hub OÜ ("PROJET", "we", "us", "our") respects the privacy of every individual and business we work with. This Privacy Policy explains what personal data we collect, how we use it, the legal grounds for processing, with whom we share it, and the rights available to you.

1. Who We Are

PROJET Hub OÜ is a private limited company registered in Estonia, operating as an authorized global wholesale distributor of sportswear, sports equipment, and related products for niche sports including darts, billiards, bowling, bocce, cornhole, padel, archery, and adjacent disciplines. Our partners are exclusively businesses (retail stores, sport federations, leagues, tournament organizers, sponsored athletes acting as commercial agents, and product brands seeking distribution).

2. Information We Collect

We collect business contact information from authorized partners and prospective partners with whom we have a documented commercial relationship or who have voluntarily reached out to us:

• Identity & contact data: business name, legal address, Tax ID / VAT number, names of authorized representatives, email addresses, mobile and landline phone numbers, social media handles voluntarily provided for business communication.
• Commercial data: order history, invoices, shipping records, dealer agreements, signed terms of trade, communication records.
• Communication content: messages exchanged via email, SMS, WhatsApp, iMessage, voice calls, and our internal CRM platform (Chatwoot-based).
• Technical data when visiting this website: IP address, browser type, pages visited, referring URL, timestamps. We do not use third-party advertising or behavioral tracking cookies on this domain.

We do not knowingly collect personal data from end consumers. We operate exclusively as a B2B distributor and do not sell or market directly to individual consumers.

3. How We Use Your Information

We process personal data exclusively for the following purposes:

• Coordinating wholesale orders, design approvals, production planning, shipments, invoicing, and after-sales service with our authorized partners.
• Sending SMS, email, WhatsApp, and iMessage communications to partners regarding orders, shipment tracking, restock notifications, dealer pricing updates, new product releases, and trade-related coordination — only to recipients who have provided their phone number or email with explicit consent for such communication.
• Maintaining accurate accounting, tax, and commercial records as required under Estonian, European Union, and applicable foreign commercial laws.
• Identifying, qualifying, and onboarding new partners through structured outreach by our Business Developer team.
• Complying with legal obligations and responding to lawful requests from competent authorities.

4. SMS Communications Program (US 10DLC / CTIA Compliance)

This section governs the SMS messaging program operated by PROJET ("the Program") for authorized US retail partners, in compliance with US carrier requirements under the A2P 10DLC framework, CTIA Messaging Principles and Best Practices, and the EU General Data Protection Regulation.

4.1 Who receives SMS

SMS messages are sent only to mobile phone numbers belonging to authorized PROJET retail partners (independent dealers, resellers, sport federations, leagues, tournament organizers, and sponsored athletes). We do not send SMS to end consumers.

4.2 How opt-in is collected

Mobile phone numbers are collected through three documented mechanisms:

• Online dealer application form at https://projet-hub.com/dealer-application — a required, unchecked-by-default consent checkbox for SMS communications must be affirmatively selected by the applicant.
• Signed dealer agreement (paper or PDF) for partners onboarded before May 2026 — Section 7 (Communications consent) of the agreement contains the opt-in consent clause. A representative sample of the consent clause is publicly hosted at https://projet-hub.com/dealer-application (lower section).
• Partner-initiated SMS contact — partners who text our designated number first are confirmed via automated welcome message before further communication is sent.

4.3 What we send

Order confirmations, shipment notifications, restock alerts, dealer pricing communications, new product releases, and ongoing trade-related coordination messages — all directly related to your wholesale account with PROJET.

4.4 Message frequency

Message frequency varies based on your wholesale account activity and partner-initiated inquiries. Typical volume is 0–10 messages per partner per week. PROJET does not send marketing broadcasts to its partner list; communications are conversational and account-specific.

4.5 Costs

Message and data rates may apply. Standard rates from your mobile service provider apply to messages sent and received under this Program. Check with your wireless carrier for details. PROJET does not charge any additional fee to participate in the Program.

4.6 Opt-out — Reply STOP

Recipients can opt-out at any time by replying STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, OPTOUT, REVOKE, or QUIT to any message. Opt-out is processed automatically by Twilio (our service provider) and a final confirmation message is sent. After opt-out, no further messages will be sent under this Program. To re-subscribe, reply START, YES, SUBSCRIBE, BEGIN, or JOIN.

4.7 Help — Reply HELP

Reply HELP to any message for automated support contact information, or email [email protected] directly.

4.8 No sharing of mobile phone numbers or SMS opt-in data — strict policy

PROJET does NOT share, rent, sell, lease, or otherwise transfer mobile phone numbers, SMS opt-in data, SMS message content, or any data collected for the SMS Program to any third party for marketing or promotional purposes — under any circumstances. This is an absolute exclusion that applies even when we share other partner data with logistics providers, production partners, payment processors, or other service providers (see Section 6).

The only third party that handles SMS-related data is Twilio Inc. (United States), our SMS service provider, which processes SMS solely for the technical purpose of message delivery on our behalf. Twilio is contractually bound by Standard Contractual Clauses and may not use SMS data for any purpose other than delivery.

Mobile phone numbers and SMS opt-in data are NEVER: shared with affiliates for marketing, sold to data brokers, used to build advertising audiences, transferred to commercial mailing-list providers, or repurposed outside the wholesale account communication scope you consented to.

5. Legal Grounds for Processing

Under the EU General Data Protection Regulation (GDPR), we rely on the following legal bases:

• Performance of a contract — for processing related to dealer agreements and active wholesale orders.
• Legitimate business interests — for partner outreach, business development, network management, and administrative communications, balanced against partner rights.
• Consent — for SMS, marketing-style email communications, and any voluntary subscription channels.
• Legal obligation — for tax, accounting, and commercial record retention required by Estonian and EU law.

6. Information Sharing

SMS-specific note: Mobile phone numbers and SMS opt-in data are EXCLUDED from any data sharing arrangement with the third parties listed below. SMS data is processed only by Twilio Inc. for technical message delivery. See Section 4.8 for the complete SMS sharing policy.

We do not sell, rent, or share partner data with third parties for marketing purposes. We share specific non-SMS information only with:

• Logistics providers (FedEx, UPS, DHL, USPS, freight carriers, customs brokers) — limited to the data necessary to deliver shipments to your business address.
• Production partners (Trident Sportswear and other authorized manufacturing partners, all based in Italy and the EU) — limited to order specifications and design files.
• Payment processors and banking institutions — limited to data necessary to process invoices and wholesale payments.
• Communication platform providers (Twilio for SMS, WhatsApp/Meta for messaging, Apple for iMessage, Zoho for email, Cloudflare for DNS) — limited to message metadata and content as required for delivery.
• Tax, legal, and accounting advisors — under strict confidentiality, only for compliance and accounting purposes.
• Public authorities — only when legally required by valid subpoena, court order, tax audit, or other applicable regulation.

7. International Data Transfers

Some of our service providers (notably Twilio, WhatsApp/Meta, Apple) operate primarily in the United States. When personal data is transferred outside the European Economic Area, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, supplementary measures where appropriate, and provider-side certifications under the EU-US Data Privacy Framework where applicable.

8. Data Retention

We retain partner business records for the duration of the partnership and up to ten (10) years after termination, in accordance with Estonian and EU commercial record-keeping requirements. Communication content is retained for as long as operationally necessary, typically up to seven (7) years. Marketing-style consent and opt-out records are retained indefinitely as proof of consent.

9. Your Rights Under GDPR (EU/EEA Partners)

If you are located in the European Union, the European Economic Area, or the United Kingdom, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data ("right to be forgotten") subject to legal retention obligations
• Restrict or object to specific processing activities
• Data portability — receive your data in a structured, machine-readable format
• Withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal
• Lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local supervisory authority

To exercise these rights, contact [email protected].

10. Your Rights Under CCPA (California Residents)

If you are a California resident acting as a representative of a US retail partner, under the California Consumer Privacy Act you have the right to know what personal data we collect and how it is used, to request deletion (subject to commercial retention obligations), and to opt-out of the sale of personal information. PROJET does not sell personal information. To exercise CCPA rights, contact [email protected].

11. Security

We implement reasonable administrative, technical, and physical safeguards to protect partner data against unauthorized access, alteration, disclosure, or destruction. These include encrypted communications (TLS 1.2+), encrypted databases, access controls, audit logging, and limited need-to-know access by our staff. No method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

12. Cookies and Tracking

This website uses only strictly necessary technical cookies for session management and security. We do not use third-party advertising, behavioral tracking, or analytics cookies on this domain. Aggregated, anonymized server logs are retained for security and operational purposes for up to 90 days.

13. Children's Privacy

Our services are directed exclusively at businesses and adults acting in a professional capacity. We do not knowingly collect personal information from individuals under the age of 18.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes. The revised version will be posted at this URL with an updated "Last updated" date. Material changes affecting your rights will be communicated to active partners via email.