RB SOLES LLC – Privacy Policy
Version 1.1 – Effective date: 2 November 2026
This policy explains how RB SOLES LLC handles personal data in connection with its B2B wholesale buyer portal at whsclub.com (the "Portal").
1. Controller
RB SOLES LLC, a Wyoming limited liability company (Wyoming ID 2025-001743027), principal office 30 N Gould St #44466, Sheridan, WY 82801, USA, trading address 2108B NW 22nd Court, Miami, FL 33142, USA, is the controller. Contact: [email protected].
2. Who this applies to
The Portal serves businesses only. We process personal data of individuals who act for business buyers and applicants (owners, employees, contacts) and of testers given access codes.
3. Data we collect
- Company and tax data: legal company name, DBA, EIN; for EU businesses in future, VAT ID. These may include personal data where a business is a sole proprietorship.
- Contact data: contact names, phone numbers, accounts-payable email.
- Delivery data: warehouse/ship-to addresses, opening hours, dock details.
- Documents: resale certificate (state, number, expiry), and optionally a business license or EIN letter.
- Login data: login email and a password stored only as a bcrypt hash (we cannot see your password).
- Transaction data: offers, counters, orders, payment status and order history.
- Acceptance records: the version of our Terms you accepted and the timestamp.
- Payment data: payment method chosen and payment status. Card and bank details are entered on Stripe's pages and are not stored by us; for wire payments we record the payer name and amount to match the transfer.
- Shipping data: ship-to address, contact name and phone, parcel weights, tracking numbers and shipping/customs documents.
- Waitlist data: if you join the waitlist: name, company, email, country, optional WhatsApp number, website/Instagram, business type and expected volume.
- Technical data: strictly necessary session and security cookies and a display-preference cookie (see our Cookie Policy); a saved delivery destination kept in your browser's local storage; and IP address and request data processed for security, rate limiting and by our network provider.
We do not use analytics or advertising tracking.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR Art. 6(1)) |
|---|---|
| Reviewing applications, running your account, handling offers, orders, payment and delivery | Performance of a contract or steps before entering one (b) |
| Keeping tax and resale certificate records, invoicing and accounting | Legal obligation (c) and, where the obligation arises under US law, legitimate interests (f) |
| Security, fraud prevention, preventing abuse and scraping | Legitimate interests (f) |
| Recording acceptance of terms; establishing and defending legal claims | Legitimate interests (f) |
| Service notices about your account and orders (e.g. payment reminders) | Performance of a contract (b) |
Providing the sign-up data is required to obtain an account; without it we cannot approve you.
5. Service providers
We share data only with providers that help us run the Portal, under contracts that limit their use of the data:
- Hetzner Online GmbH (Germany) – hosting; the database and private document folder are stored on servers in Germany.
- Cloudflare, Inc. (USA) – DNS, network proxy, tunnel and security (bot protection).
- Stripe – card and ACH payment processing via Stripe Checkout. Stripe processes payment data as an independent controller for some purposes under its own privacy policy.
- Wise and JPMorgan Chase Bank – receipt of wire/bank payments.
- Resend (USA) – delivery of transactional emails (account verification, order and payment notices).
- FedEx (Federal Express Corporation and affiliates) – shipping rates, labels, customs documents and tracking; receives ship-to name, address, phone and parcel details.
- Intuit Inc. (QuickBooks Online) – invoicing and accounting; receives company name, billing/shipping details and order lines.
- Telegram – internal notifications to our staff about new offers, applications and orders.
- Our warehouse and fulfilment systems (operated by us or our logistics partners, hosted on Cloudflare) – receive order and ship-to data to pick, pack and ship orders.
- Planned: a messaging provider for order notifications (WhatsApp Business by Meta). We will update this policy before it goes live.
We may also disclose data to our professional advisors, to authorities where legally required, or to a successor in a business transfer.
6. No sale, no automated decisions
We do not sell or "share" personal information for cross-context behavioral advertising. We do not make decisions based solely on automated processing that produce legal or similarly significant effects; every account application is reviewed by a person.
7. International transfers
RB SOLES LLC is a US company and the Portal data is hosted in the EU (Germany). Data may be transferred between the EU and the US and to providers in other countries. For transfers from the EU/EEA to countries without an adequacy decision we rely on the EU-U.S. Data Privacy Framework where the recipient is certified, or on the European Commission's Standard Contractual Clauses. Contact us for a copy of the relevant safeguards.
8. Retention
- Account and contact data: while your account is active, then up to 7 years after the last transaction.
- Transaction, invoice, tax and resale certificate records: 7 years after the end of the relevant tax year, or longer if required by law.
- Rejected applicants: 12 months after rejection.
- Acceptance records: for the life of the account plus 7 years.
- Cookies and local storage: see the Cookie Policy.
Data needed for a pending legal claim may be kept until it is resolved.
9. Security
We use encrypted connections (HTTPS), hashed passwords, access-restricted document storage, network protection and limited administrative access. No system is perfectly secure; please report concerns to [email protected].
10. Your rights (EU/EEA and UK)
You may request access, correction, deletion, restriction, data portability, and object to processing based on legitimate interests. Email [email protected]; we may need to verify your identity. Some data must be kept for legal reasons. You have the right to complain to a data protection supervisory authority, in particular in your country of residence or work.
11. US state privacy notice
The Portal is a business-to-business service. Where a US state privacy law (such as the California Consumer Privacy Act) applies, you may request to know, correct or delete your personal information, and you will not be discriminated against for exercising your rights. Email [email protected]. We do not sell or share personal information and do not use sensitive personal information to infer characteristics.
12. Children
The Portal is not directed to children, and we do not knowingly collect data from anyone under 18.
13. Changes
We may update this policy. The version number and effective date at the top show the current version. We will notify account holders of material changes.
14. Contact
RB SOLES LLC (Wyoming LLC), 30 N Gould St #44466, Sheridan, WY 82801, USA · Trading: 2108B NW 22nd Court, Miami, FL 33142 – [email protected]