Frosty Club Website & App Privacy Policy and Statement

Updated: November 30, 2025

ARTICLE I • PRIVACY POLICY APPLICATION AND CHANGES

Our Commitment to Your Privacy

Frosty Club, LLC (“Frosty Club,” “we,” “us,” or “our”) is committed to maintaining your privacy. As part of operating the Frosty Club website and mobile application (together, the “Service”), we collect and use information provided by you and generated by your use of the Service. This Privacy Policy (the “Policy”) explains what type of information we collect, how we use it, with whom we share it, and the choices you can make about the way your information is collected and used.

Scope of this Policy

This Policy applies to:

• The website located at https://frostyclub.com and any related sites that link to this Policy (the “Website”).
• The frosty club mobile application and any related software or services (the “App”).

Collectively, the Website and App are referred to as the “Service.”

Binding Effect of this Policy

By accessing or using the Service, you agree to be bound by and subject to the terms of this Policy. If you do not agree with this Policy, you must not use the Service.

Changes to this Policy

Frosty Club reserves the right, in its sole discretion, to update, modify, or supplement the terms and conditions of this Policy at any time. When we do so, we will update the “Updated Date” at the top of this page and may provide additional notice as required by law.

For users who have subscribed to receive email notifications or marketing newsletters, we may notify you of material changes via the email address you have registered with Frosty Club. All other users of the Service are encouraged to check this page periodically for updates.

Your continued use of the Service after any changes become effective constitutes your agreement to the updated Policy.

Security

The Service operates secure data networks protected by industry-standard firewall, encryption, and password-protection systems. The Service’s security and this Policy are periodically reviewed and enhanced as necessary, and only authorized individuals have access to personally identifiable information provided by users.

However, no method of transmission over the Internet or method of electronic storage is completely secure. Frosty Club does not guarantee that unauthorized or inadvertent disclosure will never occur.

ARTICLE II • KEY DEFINITIONS

Website

“Website” means the https://frostyclub.com site and any related pages, subdomains, or content managed by Frosty Club.

App

“App” means the frosty club mobile application and any related mobile or software interfaces that connect to our systems, including the Frosty Club mobile API.

Personal Data

“Personal Data” means information about an identified or identifiable natural person, such as a name, email address, phone number, or other data that can reasonably be linked to a specific individual.

Usage Data

“Usage Data” means data collected automatically, either generated by your use of the Service or from the Service infrastructure itself. Examples include device identifiers, IP address, pages visited, and duration of visits.

Cookies

“Cookies” are small data files stored on your device (computer or mobile device) that help us recognize your browser, store preferences, and understand how you use the Service.

ARTICLE III • INFORMATION WE COLLECT AND HOW WE USE IT

Automatic Anonymous Information Collected

When you visit or use the Service, we automatically collect certain technical and usage data, including but not limited to:

• Device information and type.
• Browser type and version.
• Operating system and settings.
• IP address and approximate location (city or region level).
• Access times and dates.
• Pages or screens viewed, time spent, and actions taken.
• Links clicked and navigation paths.
• Referring or exit pages.

This information is collected through server logs, cookies, and similar technologies and is used to:

• Operate and secure the Service.
• Diagnose technical issues.
• Analyze traffic and usage patterns.
• Improve content, design, and performance.
• Detect and prevent fraud, abuse, or unauthorized access.

To the extent that this information is shared with third-party analytics or service providers, it is generally aggregated or pseudonymous and is not used by those third parties to contact you directly unless you have separately provided them with your information.

Personal Data You Provide

We collect several types of information for various purposes to provide and improve our Service to you.

While using the Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to:

• First and last name.
• Business name and role or title.
• Email address.
• Phone number.
• Billing and shipping address (street, city, state, postal code, country).
• Tax ID or EIN or hemp-related license information (for eligibility verification).
• Account login credentials (username and password, which may be stored in encrypted form).
• Uploaded documents, such as business licenses, hemp permits, or resale certificates.
• Payment-related information (processed via our payment processors, described below).

We use your Personal Data to:

• Create and manage your Frosty Club wholesale account.
• Verify eligibility and legal authorization to purchase our products.
• Process and fulfill orders, including payment, shipping, and customer support.
• Communicate with you about your orders, account, or changes to the Service.
• Respond to inquiries and support requests.
• Send marketing emails or newsletters, where permitted by law and subject to your preferences.
• Improve the Service and develop new features.
• Comply with legal, tax, and regulatory obligations.

You may opt out of most marketing communications at any time by using the “unsubscribe” link in our emails or contacting us directly. Transactional emails related to your account, orders, or security cannot generally be opted out of.

Usage Data

We may collect Usage Data about how the Service is accessed and used. This Usage Data may include information such as:

• Your computer or mobile device’s IP address.
• Browser type and version.
• Device identifiers.
• The pages or screens of our Website or App that you visit.
• The time and date of your visit and the time spent on those pages.
• Unique device identifiers and other diagnostic data.

We use this data to monitor and improve the performance and security of the Service, to understand user behavior, and to help tailor user experience.

Location Data

We may use and store information about your approximate location if you give us permission to do so (“Location Data”). Location Data may be derived from your IP address or mobile device settings. We use this information to:

• Help determine eligibility for shipping or product availability by state.
• Monitor potential abuse or fraud.
• Improve and customize the Service.

You can enable or disable location services through your device or browser settings.

Tracking Technologies and Cookies

We and our third-party partners use cookies and similar technologies, such as pixels, tags, and scripts, to collect and track information and to improve and analyze our Service.

Cookies help us:

• Keep you logged into your account.
• Remember your preferences and settings.
• Understand how you use the Service.
• Tailor content and offers.

Most browsers allow you to refuse or delete cookies. If you choose to disable cookies, some parts of the Service may not function properly.

Third-party sites that are linked to from the Service may use their own cookies and tracking technologies. Frosty Club does not control and is not responsible for the data practices of those third parties.

ARTICLE IV • ANALYTICS, SESSION RECORDING, TAG MANAGEMENT AND OTHER TECHNOLOGIES

Google Analytics and Google Tag Manager

We use Google Analytics and Google Tag Manager, services provided by Google LLC, to help us understand how users interact with the Service, measure traffic and performance, and manage tracking tags.

Google Analytics uses cookies and similar technologies to collect data such as:

• IP address.
• Device identifiers.
• Pages viewed and time spent.
• Referring URLs.
• General geographic location.

This information is transmitted to and stored by Google on servers in the United States and other countries. We use aggregated data to evaluate use of the Service, compile reports, and improve our offerings.

You can learn more about how Google uses data here: https://policies.google.com/technologies/partner-sites

If you want to opt out of Google Analytics, you can install the Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout

Microsoft Clarity

We use Microsoft Clarity, a user-behavior analytics and session-recording tool, to better understand how users interact with the Website, for example clicks, scrolling, and navigation patterns. Clarity may record anonymized or pseudonymized session data, heatmaps, and analytics events, which helps us refine layout, improve usability, and diagnose issues.

Clarity may collect device identifiers, pages visited, and related technical data. Clarity does not collect sensitive fields we intentionally mask, such as passwords or full payment details. You can learn more about Microsoft’s privacy practices here: https://privacy.microsoft.com

Other Analytics and Monitoring

From time to time we may use additional analytics and error-tracking tools or services to maintain and improve the Service. The specific providers we use may change, but they will generally collect similar Usage Data and technical information as described above. We will update this Policy when we materially change the categories of such tools.

ARTICLE V • PAYMENT PROCESSORS, ORDER FULFILLMENT AND BUSINESS SYSTEMS

Payment Processing (Authorize.net)

We use Authorize.net and potentially other third-party payment processors to process payments you make through the Service.

When you submit payment information, it is transmitted directly to the payment processor and is subject to that processor’s own privacy policy and terms. We do not store your full credit card number or CVV on our servers. We may retain limited information related to your payment, such as:

• The last four digits of the card.
• Card type and expiration month and year.
• Transaction IDs, amounts, and status.

This information is used for transaction records, fraud prevention, chargeback management, and accounting.

You are encouraged to review Authorize.net’s privacy policy and terms for more detail on their data practices.

Zoho and Related Business Systems

We use various services provided by Zoho, for example Zoho CRM, Zoho Books, Zoho Inventory, Zoho Flow, and related modules, to:

• Manage leads, wholesale applications, and customer relationships.
• Sync order and invoice data.
• Track inventory and product information.
• Coordinate internal workflows and automations.

Information that may be stored or processed in Zoho systems includes:

• Contact details, such as name, email, and phone.
• Business and licensing information.
• Order and invoice history.
• Notes and communications related to your account.

Zoho systems are used for internal business purposes and are not made publicly available. Data stored in Zoho is protected according to Zoho’s security practices and policies, which you can review on Zoho’s website.

Website Platform, Forms and Shipping

• The Website is built on WordPress and WooCommerce, which store account information, order data, and related preferences in our database.
• We use form tools such as WPForms or similar technologies to capture inquiries, wholesale applications, and contact requests. These submissions may be routed into Zoho or other systems.
• To ship orders, we share necessary information, such as name, address, and contact details, with shipping carriers and fulfillment services, including USPS, UPS, FedEx, or other freight providers, solely to deliver products to you.

Cloudflare and Hosting

We use Cloudflare and other hosting or infrastructure providers to:

• Deliver the Website and App reliably and quickly as a content delivery network.
• Provide security services such as DDoS protection and web application firewalls.
• Cache content and manage DNS and SSL or TLS certificates.
• Store certain files, such as uploaded business or license documents, in managed cloud storage.

In doing so, these providers may process your IP address, device information, and access logs as part of their services.

ARTICLE VI • HOW WE USE THE INFORMATION YOU PROVIDE

Frosty Club uses the collected data for various purposes, including to:

• Provide, operate, and maintain the Website and App.
• Process and fulfill orders and payments.
• Verify your eligibility to purchase wholesale THCa and related hemp products.
• Notify you about changes to our Service.
• Allow you to participate in interactive features of the Service when you choose to do so.
• Provide customer service and support.
• Gather analysis or valuable information so that we can improve our Service and product offerings.
• Monitor the usage of the Service and detect, prevent, and address technical issues or abuse.
• Provide you with news, special offers, and general information about goods, services, and events that we believe may be of interest to you, unless you have opted out of receiving such information.
• Comply with legal and regulatory requirements, including record-keeping and tax obligations.

We do not sell your Personal Data to third parties.

ARTICLE VII • DATA TRANSFERS, RETENTION AND SECURITY

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on servers or systems located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we process data in the United States and in other locations where our service providers may operate. By using the Service and providing information, you consent to this transfer and processing.

We take reasonable steps to ensure that your data is treated securely and in accordance with this Policy.

Data Retention

We retain Personal Data for as long as reasonably necessary to:

• Provide the Service and fulfill our obligations to you.
• Comply with legal, tax, and accounting obligations.
• Resolve disputes and enforce our agreements.

When we no longer have a legitimate business need to retain your information, we will delete, anonymize, or securely store it until deletion is feasible.

Security of Data

We use commercially reasonable physical, technical, and administrative safeguards to protect your Personal Data. This may include encryption in transit, access controls, and secure development practices.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

ARTICLE VIII • OTHER DISCLOSURES

We may disclose your Personal Data:

• To our service providers, vendors, and contractors who perform services on our behalf, such as payment processing, shipping, analytics, email delivery, CRM, and IT services.
• To comply with legal obligations, such as a subpoena, court order, or other lawful request by public authorities.
• To protect and defend the rights, property, or safety of Frosty Club, our users, or others.
• In connection with any merger, sale of assets, financing, or acquisition of all or a portion of our business, subject to appropriate confidentiality safeguards.

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, analytics, or marketing purposes.

ARTICLE IX • THIRD-PARTY WEBSITES, APPS AND SERVICES

The Service may contain links to or integrations with third-party websites, applications, and services, including but not limited to:

• Payment processors, such as Authorize.net and related tools.
• CRM and business platforms, such as Zoho services.
• Embeds or plugins from Google, Microsoft, Meta, and others.

If you click on a third-party link or use a third-party integration, you will be interacting directly with that third party. Their own terms and privacy policies will apply, and we strongly encourage you to review them.

Frosty Club is not responsible for the content, security, or privacy practices of third-party websites, apps, or services.

ARTICLE X • EMAIL NEWSLETTERS, MARKETING AND YOUR CHOICES

You may subscribe to Frosty Club newsletters and marketing emails with or without placing an order.

By opting in, you agree that:

• Your name, email address, and other information you provide may be stored by our email service providers and used to send you marketing communications.
• We may track email engagement, for example opens, link clicks, and delivery status, to improve our communications and understand what content is useful.

We will not sell your email address to third parties. You may unsubscribe from marketing emails at any time by clicking the “unsubscribe” link at the bottom of any message or by contacting us.

Please note that you may still receive transactional or account-related emails, even if you opt out of marketing communications.

ARTICLE XI • CHILDREN’S PRIVACY

Our Service is intended for use by adults in connection with business purchases. The Service does not address anyone under the age of 18.

We do not knowingly collect Personal Data from children under 18. If you are a parent or guardian and you believe your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a minor without appropriate consent, we will take reasonable steps to delete such information.

ARTICLE XII • PRIVACY RIGHTS

If you are a resident of California or another jurisdiction that grants specific privacy rights, you may have certain rights regarding your Personal Data, including the right to:

• Request information about the categories of Personal Data we collect, use, or disclose.
• Request access to or a copy of your Personal Data.
• Request deletion of certain Personal Data, subject to legal exceptions.

To exercise these rights, please contact us using the information in the “Contact Us” section below. We may need to verify your identity before responding to your request.

We do not sell your Personal Data. We may share it with service providers for business purposes as described in this Policy.

ARTICLE XIII • COMMUNICATING WITH FROSTY CLUB

Any ideas, suggestions, feedback, or other communications you send to or through the Service that are not clearly intended to be Personal Data, for example feature ideas or public reviews, may be treated as non-confidential and non-proprietary. Frosty Club may use such information in accordance with its general business practices, subject to applicable law.

ARTICLE XIV • CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we do, we will:

• Post the revised Policy on this page.
• Update the “Updated Date” at the top of this Policy.

In some cases, we may also provide additional notice, such as via email or a prominent notice on the Service, if the changes are material.

You are advised to review this Privacy Policy periodically for any changes. Changes become effective when they are posted on this page, unless otherwise stated.

ARTICLE XV • CONTACT US

If you have any questions about this Policy, the practices of the Service, or your dealings with Frosty Club, please contact us:

Frosty Club, LLC
1739 Elizabeth Ave NW
Grand Rapids, MI 49504
United States

Email: [email protected]