EU-US Privacy Shield
Clubs's commitment to comply with the Privacy Shield Principles
Clubs is committed to compliance with the EU-US Privacy Shield (as set forth by the U.S. Department of Commerce) regarding the collection, use, and retention of Personal Information from European Union member countries. Clubs has self-certified that it adheres to each of the Privacy Shield Principles:
• Accountability for Onward Transfer
• Data Integrity and Purpose Limitation
• Recourse, Enforcement, and Liability
Accountability for onward transfers. The Privacy Shield Principles describe Clubs's responsibility for Personal Information that it receives from EU residents under the Privacy Shield and subsequently transfers to a third party processor. In particular, if Third Party Agents that process Personal Information on Clubs's behalf do so in a manner inconsistent with the Privacy Shield Principles, Clubs will remain responsible and liable unless it can prove that it is not responsible for the event giving rise to the damage.
Right of access. You have a legal right to request a copy of the Personal Information that we have about you. You also have a right to correct, amend or delete such Personal Information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.
Resolution of disputes and complaint mechanism. In compliance with the Privacy Shield Principles, Clubs commits to resolve complaints about your privacy and our collection or use of your Personal Information. If European Union citizens have any queries related to the processing of your Personal Information under the Privacy Shield framework, we encourage you to contact us directly in the first instance at: privacy@Clubs.com or Clubs Privacy, Witan Gate House, 500-600 Witan Gate West, Milton Keynes, MK9 1SH.
For any complaints that cannot be resolved with Clubs directly, we have agreed to cooperate with JAMS. If you are unsatisfied with the resolution of your complaint, you may contact JAMS for further information and assistance. These recourse mechanisms are available at no cost to you.
Binding arbitration. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints regarding Clubs's Privacy Shield certification not resolved by any other means.
Enforcement. Clubs is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Disclosure of EU personal data to public authorities and law enforcement agencies. Clubs may be required to share your Personal Information in response to lawful requests by public authorities. Interest-Based Advertising in the EEA or Switzerland
For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit http://youronlinechoices.eu/
. Residents of France
You have the right to give Clubs instructions concerning the use of your Personal Information after your death. You can exercise this right by contacting us here.
Clubs does not knowingly collect Personal Information from children under 15 years of age in France. The Clubs is not directed to children under the age of 15 and children under 15 are not permitted to use the Clubs. If we become aware that we have unknowingly collected Personal Information from a child under the age of 15, we will delete or disable such information. If you are a parent or guardian of a child under the age of 15 and you believe that your child has provided us with Personal Information, please let us know by contacting us here. Residents of Spain
Clubs does not knowingly collect Personal Information from children under 14 years of age in Spain. The Clubs is not directed to children under the age of 14 and children under 14 are not permitted to use the Clubs. If we become aware that we have unknowingly collected Personal Information from a child under the age of 14, we will delete or disable such information. If you are a parent or guardian of a child under the age of 14 and you believe that your child has provided us with Personal Information, please let us know by contacting us here. D. Residents of Canada.
Custom Audience. We may use services provided by third-party platforms (such as social networking or other websites) to serve targeted advertisements on such platforms to you, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please launch the opt-out tool at https://youradchoices.ca/choices
Interest-Based Advertising in Canada. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit https://youradchoices.ca/choices
To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC's AppChoices tool, please download the version of AppChoices for your device at https://youradchoices.ca/appchoices/
. Exhibit A
Type of Cookie Purpose Who Serves (for example)
Authentication Cookies These cookies (including local storage and similar technologies) tell us when you're logged in, so we can customize your experience and connect your account information and settings. • Clubs
Localization These cookies help provide a localized experience by showing you your local metro area. • Clubs
• Amazon- Hosting
• MyFonts Counter
• Google Analytics
• Google Tag Manager Interest-Based Advertising
Things like cookies and pixels are used to deliver relevant ads, track ad campaign performance and efficiency, and to understand your interests from your online activity on the Site, mobile applications and other websites and apps. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites and in doing that your information (which will not contain your name, email address or other "real-world" identifiers) will be shared with other platforms in the digital advertising ecosystem all involved in assisting the delivery, purchase, reporting and analysis of digital advertising. Similarly, our advertisers may use a cookie, attribution service or another similar technology to determine whether we've served an ad and how it performed, or provide us with information about how you interact with them.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes, including analytics, and you may still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser's instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser's saved cookies, you may need to opt-out again.
For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative opt-out page, or the Digital Advertising Alliance's opt-out pages in the United States, https://youradchoices.ca/choices/
in Canada, or http://youronlinechoices.eu
in the EU.
• Horizon Social Media and Digital Advertising cookies and widgets
• DoubleClick: Google's Doubleclick re-targeting cookie lets us serve personalized ads to you when you're browsing other websites and social media platforms. You can control ad personalization on Google and partner websites In Google's Privacy and Terms page.