TERMS, COOKIES AND DATA

Twelve provides ticketing, loyalty and supporter financing infrastructure to football clubs. This page covers the public website at twlv.lu: the terms on which you may use it, the personal data we collect through it, and the law that governs both.

Club portal accounts and services delivered to a club are governed by the agreement signed with that club. Where a club uses Twelve to process data about its own supporters, the club is the controller of that data and Twelve acts as its processor.

The content of this site is published for information. It describes a product for football clubs. It is not an offer to sell or a solicitation to buy any security or financial instrument, and it is not investment, legal or tax advice.

Figures and examples shown on this site are illustrative unless they are explicitly attributed to a named source. Product screens are exports of our own application.

The site, its text, design, code, images and marks belong to Twelve or its licensors. You may read, quote briefly with attribution, and link to it. You may not copy it wholesale, scrape it in bulk, resell it, or use it to train a model without our written permission.

You agree not to disrupt the site, probe it for vulnerabilities without authorisation, or use it in breach of any law. We may change or withdraw any part of the site at any time, and we do not promise uninterrupted availability. Links to other websites are provided for convenience and we are not responsible for their content.

To the extent permitted by law, Twelve is not liable for indirect or consequential loss arising from the use of this website. Nothing in these terms limits liability for fraud, for death or personal injury caused by negligence, or for anything else that cannot lawfully be limited.

When you contact us, we collect your name, your club or company, your email address, your phone number, the topic you choose and the message you write.

When you subscribe to Matchday Intelligence, we collect your email address and the page you subscribed from.

When you browse the site, we record which pages and buttons were used, together with a random identifier for your browser, a random identifier for the visit, the page you arrived on, the site that referred you, and any campaign parameters in the address you followed, such as utm_source, utm_medium, utm_campaign, gclid, fbclid and ref. Your chosen language is stored so the site opens in it next time.

We do not ask for special category data, and we do not want it. Please do not send it to us in a message.

Enquiry details are used to reply to you, to prepare and hold a demo, and to progress a possible working relationship with your club.

Newsletter details are used to send Matchday Intelligence and nothing else.

Browsing and campaign data are used for marketing: to measure which campaigns, channels and pages actually bring clubs to us, to see where people lose interest, and to improve the site and the way we describe the product. We also use business contact details to approach clubs about Twelve.

We do not sell personal data. We do not share it with third parties for their own advertising. We do not build profiles that produce legal effects or similarly significant effects for anyone, and we do not take automated decisions of that kind.

Under Article 6 of the General Data Protection Regulation, and the Luxembourg law of 1 August 2018 on the organisation of the National Commission for Data Protection, we rely on the following.

• Consent, Article 6(1)(a). Sending you Matchday Intelligence, and storing anything on your device that is not needed to deliver the site. You may withdraw consent at any time and it stays lawful up to that point.
• Contract and steps before a contract, Article 6(1)(b). Answering your enquiry, arranging a demo, and running an account you hold with us.
• Legitimate interests, Article 6(1)(f). Measuring our own campaigns and pages, keeping the site secure and available, and contacting clubs as organisations about a product that serves them. Our interest is running and growing a business. We weigh it against your interests, and you may object at any time.
• Legal obligation, Article 6(1)(c). Keeping accounting records and answering lawful requests from an authority.

Some storage is strictly necessary: it keeps your session on the club portal, remembers your language, and keeps the site secure. The site cannot work without it, so it is set without asking.

The rest is measurement, described in section 3: a random visitor identifier, a visit identifier and campaign parameters, held in your browser's local storage rather than in a third-party advertising cookie. It is not needed to deliver the site, so it belongs to you to allow or refuse.

We run no third-party advertising or retargeting tags. If that changes, this page changes with it, and consent is asked for before any such tag loads.

You can clear this storage at any time in your browser settings, usually under privacy, cookies and site data. Blocking it does not stop you using the site, and only the strictly necessary items return.

We use service providers to run the site and our email: hosting and application infrastructure, a database and authentication provider, and an email delivery provider that sends Matchday Intelligence. They act on our documented instructions under a data processing agreement, and they may not use your data for their own purposes.

Where a provider processes data outside the European Economic Area, the transfer rests on a European Commission adequacy decision or on standard contractual clauses, with additional safeguards where they are needed.

We disclose personal data to an authority only where the law requires it, and to a professional adviser where we need advice.

Enquiries are kept while a possible relationship with your club is live, and for up to three years after our last exchange, so we know what was already discussed.

Newsletter subscriptions are kept until you unsubscribe, and the record of the unsubscribe is kept so we do not write to you again.

Measurement data is kept for up to fourteen months. Accounting records are kept for ten years, as Luxembourg commercial law requires.

You may ask for a copy of your data, ask us to correct it, ask us to delete it, ask us to restrict how we use it, ask for it in a portable form, object to a use based on legitimate interests, and withdraw any consent you gave.

Write to hello@twlv.lu. We answer within one month. Every Matchday Intelligence email also carries a one-click unsubscribe link.

If our answer does not satisfy you, you may complain to the Luxembourg supervisory authority, the Commission nationale pour la protection des données, at cnpd.public.lu, or to the authority where you live or work.

These terms, this page, and any dispute or claim arising out of the website or its subject matter, including a non-contractual one, are governed by the law of the Grand Duchy of Luxembourg.

The courts of the City of Luxembourg have exclusive jurisdiction, save that a consumer keeps the protection of the mandatory rules and the courts of their country of residence, where the law gives them that right.

We update this page when what we do changes. The date at the top is the date of the current version. Continuing to use the site after a change means you accept the terms as they then stand.

This page is published in English. Translations are provided for convenience, and the English version prevails.