Twelve Privacy Policy
 
Last updated: July 9, 2024
 
This Privacy Policy details how Twelve Benefit Corporation (“Twelve”, “we”, “us”, and “our”) collects, uses, discloses and secures your personal information:
 

• When you visit or interact with our website at https://www.twelve.co/or any subdomains thereof (“Site”);

• any of the information, content, tools, services, or Materials (as defined in the Terms of Service) made available via this Site; and

• When you otherwise communicate with us, such as through email (collectively with the Site, all of the foregoing are the “Services”).
   

Your use of our Services is at all times subject to our Terms of Service (“Terms”) at https://www.twelve.co/termsofservice, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.     

 
Although Twelve is not currently subject to the California Consumer Privacy Act or the EU’s or the UK’s General Data Protection Regulation (“GDPR”), we may use the terms ‘controller’ and ‘processor’ or ‘service provider’ as they are commonly understood under applicable privacy laws. We act as a ‘Data controller’ when we collect personal information on our own behalf and for our own commercial and business purposes, such as from Site visitors or to register customers, to improve our Services or send marketing emails. 

How to Contact Us about Privacy

Any questions about this Privacy Policy or requests for access to or deletion or rectification of personal information that Twelve collects and processes should be addressed to us at privacy@twelve.co.


Personal Information We Collect

 We collect information directly from you when you provide it to us, such as when visit our Site. We also collect information indirectly, such as through the use of cookies and similar technology.
 
We collect the following categories of personal information:

• Identifiers or contact information, such as a real name, IP address, phone number, and email address

• Personal information categories such as a name, signature or telephone number

• Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• Internet or other similar network activity, such as browsing history or information on a user’s interaction with a website

• Professional or employment-related information

 
We may also collect the following information, which does not fall within the definition of “personal information” that we use in the Privacy Policy:

• Publicly available information from government records.

• Deidentified or aggregated personal information.

• Certain other information that is already regulated by other laws or regulations.

Twelve will not collect additional categories of personal information (including sensitive personal information) or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 
Twelve does not collect protected classifications characteristics under applicable privacy laws, such as biometric information, sensory data, or non-public education information. 

Information Collected Directly from You
Communicating With Us

When you visit the Site, you may choose to fill out a web form, such as on our “Contact Us” page. In this case, you are sharing your personal information with us directly. Information that we collect from you consists of:
 

• Name

• E-mail address

• Phone Number

• Company name 

• Other information you may provide in the message box
   

In addition, if you send us an email or otherwise contact us, we will collect the personal information that you provide to us at that time.
 
Information Collected Indirectly
 
When you visit the Site, we collect some information, including Device and Usage Information described below, using automated means such as cookies, web beacons, SDKs and server logs. For more information on our use of these technologies and the data that they collect, please see our Cookie Statement below.
 
Device and Usage Information
 
When you visit, use or interact with the Site and/or Services, we may collect information about your use of the Site and/or Services via your device. Device and Usage Information that we collect consists of:
 

• Information About your Device: information about the devices and software you use to access the Site and/or Services. This primarily includes the internet browser or mobile device that you use your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information.

• Usage Information: information about your interactions with the Site and/or Services. This includes analytics such as device type, access dates and times, and hardware and software information. For example, this information allows us to understand what percent of our users are on a tablet or a mobile device, and what other actions our users take on the Site and/or Services. The usage information collected is aggregated and is not correlated to any specific individual.  . We use this information to administer and improve the Site, analyze trends, track visitors’ use of the Site, and gather broad demographic information for aggregate use.

• Location Data: we may collect your location data through your IP address or if your mobile device permits such collection.

 
Why We Collect Your Personal Information and How We Use It
 
We collect and process personal information for the following purposes in order to:

• Provide the Site and Services

• Ensure that the Site and Services are operational and optimized for user experience

• Improve the content and general administration of the Site and Services

• Enhance customer experience, including to provide customer support

• Detect, prevent and investigate fraud, illegal activities, unauthorized access to or use of our Services, security breaches or any other wrongful behavior/behavior

• Deliver content and tailored advertising, and generally market and advertise Services

• Ensure compliance with mandatory retention requirements

• Provide you with notices regarding Services that you have purchased

• Provide you with notices regarding Services that you may wish to purchase in the future including, in some cases, to send you direct marketing communications regarding other services that we may think are of interest to you

• Respond to your queries and requests, or otherwise communicate directly with you

• Perform system maintenance and upgrades, and enable new features

• Understand how you access and use the Site and Services in order to provide technical functionality and/or develop new products and services

• Conduct statistical analyses and analytics based on usage and activity on the Site

• Enforce our agreements with you if necessary

• Provide information to regulatory bodies when legally required, and only as outlined in this Privacy Policy

In some cases, we combine or aggregate the information for the purposes stated above
 
Disclosure of Your Personal Information
 
We disclose your personal information under certain circumstances with third parties and our service providers. 
 
Twelve may share personal information with our third party agents, contractors, or service providers who are hired to perform services on our behalf or in order to assist with certain business purposes. These providers may operate or support certain functions of the Site and/or Services. Below is a list of categories of service providers that we may use to perform these functions (which are subject to change):

• Analytics services

• Customer support services

• Billing services and payment gateway providers

• Hosting and content delivery network services

• Communication tools

• Professional services (such as auditors, lawyers, consultants, accountants and insurers)

• Customer Relationship Management (CRM) solutions

 
Such service providers process your personal information for the specific purpose of providing their services to us (and in accordance with our instructions and security standards). In some cases, service providers may collect your personal information directly from you, such as via cookies. 
 
Business Transfers
 
As we continue to grow, we may purchase websites, applications, subsidiaries, or other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities, obtain financing, and/or sell assets or stock, in some cases, as part of a reorganization or liquidation in bankruptcy. In order to evaluate and/or as part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation, or other corporate reorganization in which Twelve participates, to investors and/or to a purchaser or acquirer of all or a portion of Twelve’s assets, including bankruptcy.
 
Legal Obligations and Security
 
Twelve may preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when Twelve reasonably believes it is necessary to respond to lawful requests or it is required by law, such as pursuant to a valid subpoena, warrant, or other judicial or administrative order  or other legal process such as detecting and investigating security incident and potentially illegal or prohibited activities; (iii) to protect the safety of any person; (iv) to protect the safety or security of the Site and/or Services or to prevent spam, abuse, or other malicious activity of actors with respect to the Site and/or Services; or (v) to protect our rights or property and/or the rights or property of those who use the Site and/or Services.
 
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant, or other judicial or administrative order, we will use reasonable efforts to provide you with notice of this disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty), and to object to requests that we do not believe were issued properly. However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), which will be determined on a case-by-case basis.
 
International Transfers
 
We are located in the United States. The personal information that we collect is stored on servers hosted by us or our authorized third-party service providers located in the United States. This means that your personal information will be collected, processed, and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR. However, we are not subject to the GDPR at this time as a controller.

By using our Services or our Site, you agree and consent to the processing of your personal information on servers located in the United States, which may not offer an equivalent level of protection to that required in other regions (particularly the European Union or the U.K.).
 
We have implemented safeguards we believe are designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy, including when processed internationally or by our third-party service providers and partners. The safeguards we may take in our discretion include, for instance, relying on mechanisms such as Standard Contractual Clauses (“SCCs”) if we are acting as a processor, to comply with applicable laws.
 
Children’s Information

Our Services do not target anyone under the age of 13. We do not knowingly collect personal information directly from children. If you are under the age of 13, please do not submit any personal information through our Services. 
If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we may delete such information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on our website and/or our Services without their permission.
If we discover we have inadvertently received any personal information from a child under the age of 13 in violation of this Privacy Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe that we have any personal information from or about anyone under the age of 13, please contact us at privacy@twelve.co.
Social Media Plug-Ins
We use social media plug-ins (e.g., LinkedIn and Instagram). These features may collect your IP address and/or other information as set forth in each social platform’s privacy policy, which page you are visiting on our Sites or Services, and may set a cookie to enable the feature to function properly. Twelve also has a presence on some social media platforms, including LinkedIn, Instagram and others. Through our accounts on social medial platforms, we may in some instances collect personal information when you interact with the Twelve accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.
Your Rights
You may have the right to submit certain requests relating to your personal information as described below based on applicable laws. Please email us at privacy@twelve.co to submit data requests. 

• Right to access and data portability. You can request and receive a copy of the Personal Data we have collected, used, or otherwise processed and you can confirm what Personal Data has been collected. 

• Right to correct inaccuracies. You can request that we correct any inaccurate Personal Data we may have.  

• Right to delete. You can request deletion of your Personal Data. 

• Right to opt-out.  You can opt-out of targeted advertising, the sale of your Personal Data or limited sharing of your Personal Data. 

• Right to appeal. At times we may be unable to process requests relating to your Personal Data, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request via emailing privacy@twelve.co[. 

Please note that we may need to authenticate your identity before your request can be processed, providing us with 2-3 pieces of personal information which we will match to information we maintain about you. For authentication, you may be asked to provide certain personal information that we will match against our records. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. 
Non-Discrimination
We will not discriminate against you in a manner prohibited by the applicable state laws because you exercise your privacy rights. While you may request to delete your personal information, such deletions may affect our ability to offer the Services to you.
 
Google Analytics
 
We may use Google Analytics. You can read more about Google’s practices in Google’s privacy policy, here: https://policies.google.com/privacy. You can opt-out from being tracked by Google Analytics in a particular browser on a particular device by downloading and installing the Google Analytics Opt-out Browser Add-on for that browser.
 
Marketing & Advertising
 
Direct Marketing
 
We market and advertise our company and Services in a variety of ways. We may gather information from or about you in the following different roles:

• Individuals who have visited the Site

• Individuals, entities or others who have contacted Twelve or otherwise inquired about Twelve’s Services

• Customers

Our communications to you for marketing purposes will contain instructions on how you can opt-out from receiving future communications, and if you consent to our use of your personal information for marketing purposes, you may always withdraw your consent by clicking “Unsubscribe” or you may contact us at privacy@twelve.co.  
 
How We Secure Personal Information
 
We use reasonably appropriate security measures designed to protect the security of personal information both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.
 
Do Not Track Signals
 
Certain internet web browsers allow a “do not track” (DNT) setting that relies on a technology known as a DNT header, which sends a signal to websites visited by the individual about the individual’s browser DNT setting. At this time, we do not currently respond to DNT signals, whether that signal is received on a computer or on a mobile device. 
 
Cookies
 
This section describes how we use cookies (and what they are) and the choices that you have to manage the cookies that we use. Throughout this Cookie Notice, we use capitalized terms defined in the Privacy Policy.
 
What are Cookies?
A cookie is a small text file stored on your computer, tablet or mobile phone that makes it possible to save and track data about your use of our Site –including personal information. Some cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for analytics, functionality as well as advertising and marketing efforts. Other technologies (such as software developer kits or SDKs, web beacons and pixels) work in the same manner as cookies to collect information from about you, as explained in our Privacy Policy. Through the use of these technologies, we collect Device Information, Usage Information, as defined and explained in the Privacy Policy.
 
Types of Cookies
 
We use the following types of cookies on our Site and in our Services.
 
Strictly Necessary Cookies

These cookies are necessary – or “essential” – for the Site to function and cannot be switched off in our systems. They are mostly only set in response to actions made by you, such as setting your privacy preferences, logging in or filling informs. You can set your browser to block or alert you about these cookies, but if you do block them, some portions of the Site will not work. These cookies do not store any personally identifiable information.

 
Targeting Cookies

These cookies may be set through our site by our advertising and marketing partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites (e.g., retargeting), including social media platforms. Note that when targeting cookies are dropped, your personal information (such as Device Information) will be shared with multiple other parties with whom Twelve does not have a relationship.
 
Managing your Cookie Preferences

You can disable and/or delete cookies from your computer, tablet or mobile phone by managing your browser settings. How to manage and disable cookies depends on your browser, so you should visit your browser settings for more information.
 
Interest-Based Advertising
 
Some of the advertisers and service providers that perform advertising-related services for us may participate in the by Digital Advertising Alliance (DAA) or the Network Advertising Initiative's (NAI). You may visit www.aboutads.info to receive more information about the collection and use of information about your online activities for interest-based advertising, or to learn how to opt-out of having your data used for interest based advertising by DAA participating companies. The NAI Opt-Out Tool at www.networkadvertising.org/choices allows you to opt out from the use of information about your online activities for interest based advertising by NAI member companies.
 
Changes to this Privacy Policy
 
Twelve may update this Privacy Policy from time to time, in its sole discretion. If we do so, we will post an updated Privacy Policy on the Site. Changes, modifications, additions, or deletions will be effective immediately upon their posting to the Site. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or Services, and/or your continued provision of personal information to us after the posting of such notice, will be deemed an acceptance of any changes and subject to the terms of the then-current Privacy Policy.
 
Contact Us

If you have any questions about this Privacy Policy, you can contact us at Twelve Benefit Corporation by email at privacy@twelve.co, or by mail at the address below: 
 
614 Bancroft Way Suite B
Berkeley, CA 94710 
United States