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:
• Notice
• Choice
• Accountability for Onward Transfer
• Security
• Data Integrity and Purpose Limitation
• Access
• Recourse, Enforcement, and Liability
If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit here.
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. Transfer Of Data. We and our affiliates and Third Party Agents primarily store data about you, including Personal Information, on servers located and operated within the United States. If you reside or are located outside of the U.S., we may send and store your Personal Information (also commonly referred to as personal data) to the U.S. in order to provide and operate the Clubs. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your Personal Information on servers located in the U.S. and other countries.
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
Site features and services These provide functionality that helps us deliver products and the Clubs. For example, cookies help you log in by pre-filling fields or help ensure older versions of web browsers can still view our Site(s). We may also use cookies and similar technologies to help us provide you with social plugins and other customized content and experiences, including customized fonts.
• Clubs
• Facebook
• Linkedin
• Amazon- Hosting
• Zopim
• Polyfill
• MyFonts Counter
Analytics and research These are used to understand, improve, and research products and services, including when you access the Clubs and related websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, to report on any errors in how the Site is functioning, to report to our vendors when content licensed from them is assessed, and to segment audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services, and ads.
• Google Analytics
• HeapAnalytics
• MixPanel
• BugSnag
• 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.
• Clubs
• Google
• Doubleclick
• Sailthru
• 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.
• Facebook Connect: We may allow you to sign up and log in using your Facebook account. If you sign up using Facebook Connect, Facebook will ask your permission to share certain information from your Facebook account with us. This may include your first name, last name, email address, profile picture, and general location in order to create an account. This information is collected by Facebook and is provided to us under the terms of Facebook's privacy policy. You can control the information that we receive from Facebook using the privacy settings in your Facebook account.
• Facebook Impressions: We use Facebook Impressions to track the number of people that interact with our content on Facebook. This information is collected by Facebook and is provided to us under the terms of Facebook's privacy policy. You can control the information that we receive from Facebook using the privacy settings in your Facebook account.
• Google Sign-in: We may allow you to sign up and log in using your Google account. If you sign up using Google, Google will ask your permission to share certain information from your Google account with us. This may include your first name, last name, email address, profile picture, and general location in order to create an account. This information is collected by Google and is provided to us under the terms of Google's privacy policy.
• LinkedIn Widgets: This tool enables visitors to engage with us via LinkedIn and show visitors relevant ads and personalized content on LinkedIn. To learn more about LinkedIn's practices and to opt out, please visit LinkedIn's Privacy Policy and Settings.
• Sailthru: Email newsletters you elect to receive from us are transmitted through Sailthru. Sailthru uses pixel tag technology to determine whether an email has been opened. In addition, when you click on any link in an email newsletter or marketing message you have elected to receive, Sailthru recognizes that fact. This information is used in the aggregate to measure the rate at which emails are opened and various links are clicked, to measure user interests and traffic patterns, and to improve the content of the email newsletters and the services and features offered through the email newsletter and marketing messages. Because some of this information is linked to individual email addresses, it is personally identifiable. You can view Sailthru's privacy policy here.
Other cookies • Google Analytics: We use Google Analytics, a web analytics service. Google Analytics uses cookies to help Clubs analyze how visitors use the Site(s). The information generated by cookies about your use of the Site(s) and the Clubs (including your IP address) will be transmitted to and stored by a Google server in the United States. Google uses this information for the purpose of evaluating your use of the Site(s), compiling reports on Site activity for Site operators, and providing Site operators with other services relating to Site activity and Internet usage. You can prevent the storage of data relating to your use of the Site(s) and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available here. You can obtain additional information on Google Analytics' collection and processing of data and data privacy and security at the following links: How Google Uses Information From Sites Or Apps That Use Our Services and Analytics Help.