# Privacy Policy ## **CLUBCREATORS INC PRIVACY NOTICE** ClubCreators Inc. ("Club", "we", "our", or "us") is committed to safeguarding and processing personal data in line with all applicable privacy and data protection laws. This policy describes how we collect, process, retain, and disclose PI when providing services to you through our websites, applications, and services that link to this policy (our "Services") and our practices for using, maintaining, protecting, and disclosing that information. References to “you” or “your” refers to individuals whose personal data is processed by Club. This policy applies only to personal data we process * Through provision of the Services to you as either a potential or actual customer. * In communications, including email, text, chat, and other electronic messages, between you and the Services. * When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. It does not apply to information collected by: * Us offline or through any other means, including on any other website operated by Club or any third party that does not link to this policy; * Employment-related personal data processed about Club employees or role applicants; or * Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services. We may provide additional or different privacy policies that are specific to certain features, services, or activities. Please read this policy carefully to understand our policies and practices regarding your personal data and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your personal data as described in this privacy policy. This policy may change from time to time, as described below. Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates. \ CHANGES TO OUR PRIVACY POLICY We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "Last Modified" date, above, and posting the updated policy on the Services. If you have an account, we may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it. \ CHILDREN'S AND MINORS' PERSONAL DATA Our Services are not intended for users under 18 years of age and no one under 18 years of age is permitted to create an account with the Services. No one under age 18 may provide any information, including any personal data, to or on the Services. We do not knowingly collect personal data from children under 18. If you are under 18, do not use or provide any personal data on the Services or through any of its features, register on the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal data from a child under 18, we will delete that information. If you believe we might have any personal data from or about a child under 18, please contact us at . THE PERSONAL DATA THAT WE COLLECT OR PROCESS "Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, or any other identifier we may use to contact you online or offline). The types and categories of personal data we collect or process include: * Account and contact information, including name, address, email address, phone number, username, and other contact information you provide us. * Account history, including information about your subscription, account, usage, transactions, purchases, order history, or discounts. * Identification information, including driver’s license or state identification card number, social security number, individual taxpayer identification number (ITIN), passport number, and other similar government identifiers. * Geolocation data (imprecise and limited to city and state). * Biometric information, including facial recognition. * Payment information, including bank account number and credit or debit card information. * Demographic information, including your age, gender, income level, education, or family or marital status, if you have consented to such information collection. * Location information, including general geographic location such as country, state or province, or city. * Device and usage information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, geolocation data, and other device and usage information. * Content and information you elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us. * Images, voice recordings, and videos collected or stored in connection with the Services, if you have consented to such information collection. To the extent you engage in any communications with us, including emails, chats, or communications made available through other methods or channels of communication, we will retain a copy and/or transcript of such communications. Your use of such communication features constitutes your consent and agreement to such retention. If required under applicable law, we will collect and process sensitive personal data and/or biometric data only with your consent. If you choose not to provide or allow us to collect some personal data, we may not be able to provide you with requested features, services, or information. We also collect: * Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature. * Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), pages that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page. If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data. We may deidentify or aggregate your personal data so that it can no longer be used to identify you, and may use or disclose this deidentified data for any purpose, including for research, product improvement, and analytics, without restriction. We manage deidentified data in line with the requirements under Cal. Civ. Code § 1798.140(h). HOW WE COLLECT YOUR PERSONAL AND OTHER DATA You Provide Information to Us We collect personal data about you when you interact with our Services, such as when you create or update an account, participate in surveys, sweepstakes, contests, or promotions, or create, upload, or post content to the Services, including reviews, media such as photos, videos, chats, or audio recordings. Automatically Through Our Services As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use. We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience. The technologies we use for this automatic data collection may include: * Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services. * Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Club, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may include: * Our service providers, such as for chat services, error and bug tracking, help center, notifications, payment services, identity verification services, or text message notification services (if you have opted-in) * Advertisers, ad networks, and ad servers * Analytics companies * Your internet or mobile service provider These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. From Business Partners and Service Providers We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, content delivery services, promotions services, and analytics, security and anti-fraud services. We also may receive personal data from business partners that we engage to share consumer information with us, including your personal preferences and demographic information such as age, gender, and income level so that we can better provide you with a personalized experience, including personalized content, offers, and services. HOW WE USE YOUR INFORMATION We use information that we collect about you or that you provide to us, including any personal data, to: * Provide you with the Services and any contents, features, information, products, or services that we make available through the Services. * Fulfill any other purpose for which you provide it. * Provide you with notices about your account, including expiration and renewal notices. * Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training. * Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services. * Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. * Notify you when Services updates are available and about changes to any products or services we offer or provide though them. * In any other way we may describe when you provide the information. * For any other purpose with your consent. The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to: * Estimate our audience sizes and usage patterns. * Store information about your preferences, allowing us to customize the Services according to your individual needs and interests. * Speed up your searches. * Recognize you when you return to our Services. \ WHO WE DISCLOSE YOUR INFORMATION TO We may disclose aggregated and deidentified information about our users without restriction. We may also disclose personal data that we collect or you provide as described in this privacy policy: * To our subsidiaries and affiliates. * To other users of the Services (subject to the settings you have made with respect to posts, User Contributions, chats, and other communications within the Services). * To contractors, service providers, and other third parties we use to support our organization. * To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ClubCreators Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by ClubCreators Inc. is among the assets transferred. * To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see [the](https://docs.google.com/document/d/16q2XGHG1tz9wSBI3izpKAxpvNhe5_p9P/edit#bookmark=id.c0rbridhy62g) “YOUR RIGHTS AND CHOICES ABOUT YOUR INFORMATION” section below. * To fulfill the purpose for which you provide it. * For any other purpose disclosed by us when you provide the information. * With your consent. We may also disclose your personal data: * To comply with any court order, law, or legal process, including to respond to any government or regulatory request. * To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes. * If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. The categories of personal data we may disclose include: * Account and contact information. * Account history, including information about your subscription, account, transactions, usage, purchases, order history, or discounts. * Demographic information. * Location information, including general geographic location. * Device information. * Content and information you elect to provide to us. * Images, voice recordings, chats, and videos collected or stored in connection with the Services, if you have consented to such information collection, including the retention of transcripts of communications you have with us. YOUR RIGHTS AND CHOICES ABOUT YOUR INFORMATION This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live. Advertising, marketing, cookies, and other tracking technologies choices: * Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by making elections within your browse and choose not to allow cookies. Strictly necessary cookies, which allow the website to function, are always used and cannot be turned off. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy. * Promotions by Club. If you do not wish us to use your personal data to promote our own or third parties' products or services, you can opt out by sending us an email stating your request to or clicking the "unsubscribe" link found at the bottom of commercial emails from Club. * Targeted Advertising by Club. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target audience preferences, you can opt out by sending us an email stating your request to . * Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out by sending us an email stating your request to or by using any other features made available by Club for this purpose. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted ads from members of the Network Advertising Initiative ("NAI"), including how to add the NAI Global Privacy Control (GPC) extension to your Chrome web browser, see NAI: [How to Opt Out](https://thenai.org/how-to-opt-out/). Your Privacy Rights You can review and change your personal data by logging into your account or by sending us an email at to request access to, correct or delete any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. California's "Shine the Light" law (Cal. iv. Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided in the “Contact Information” section below, indicating that you are submitting a request under the California “Shine the Light” law. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request using the email or address in the “Contact Information” section below. However, please know we do not currently sell personal data in any manner that would trigger that statute's opt-out requirements. The owner of the Website is incorporated in the State of Delaware in the United States and is headquartered in the State of New York in the United States. We provide the Website for use only by persons located in the United States. Non-U.S. persons visiting from other countries should be aware that, by visiting the Website, you are agreeing to be subject to U.S. privacy laws rather than the laws of your home country. If you access the Website from outside the United States, you do so on your own initiative, consent to the transfer of your personal data to the United States, consent to the use of your personal data as in this privacy policy and are responsible for compliance with local laws. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal data used in completing that transaction may be subject to disclosure under United States legislation, including the PATRIOT Act. Non-U.S. persons shall have the same rights as U.S. persons as described in this privacy policy. Exercising those rights is free of charge. Should you have any issues or complaints, we hope you will contact us directly using the information provided in the “Contact Information” section below, although you may have the right to also contact the data protection supervisory authority where you reside if you wish to do so. How We Protect Your Personal Data We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk. The safety and security of your personal data also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access. How We Retain Your Personal Data We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified. INTERNATIONAL TRANSFERS To provide global services and in the course of running our business, we may transfer personal data to a location outside the country where you reside or where services are provided to you, including Club’s processing centers in the US, Serbia, and Australia. Although the country to which personal data may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of personal data wherever it is processed. CONTACT INFORMATION To ask questions or comment about this privacy policy and our privacy practices, exercise your rights under applicable data protection laws, connect with our Data Protection Officer (DPO), or to register a complaint or concern, contact us at: ClubCreators Inc. ATTN: Data Protection Officer (DPO) 6 Harrison Street Fl. 5 New York, NY 10013 USA Email: To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection to exercising your rights.