Club b Privacy Policy

Privacy Policy

Last Updated and Effective as of: January 17, 2023

Introduction

Club b, a stand-alone subsidiary of Real Vision Group SEZC (collectively, “Club b,” “we,” “us,” and “our”), wants you to be familiar with how we collect, use and disclose information from and about you because we understand you are concerned about your privacy, and we want to maintain your trust.

Your personal privacy and the privacy of your data is paramount to us at Club b. We have prepared this Privacy Policy expressly for Club b clients to clearly explain how we collect, process, and protect your data at Club b.

This Privacy Policy applies to information we collect from our website at https://leclubb.com/ (“Site”) and our applications (“Apps”, together with Site, referred to below as the “Club b Services” or the “Services”) that link to this Privacy Policy. This privacy policy does not apply to any other websites, Apps or services provided by us, our affiliates or clients, unless it appears on such website, App or service.

Your use of our Services is also governed by the Terms of Use published at https://www.realvision.com/terms/ (“Terms of Use”).  By using the Club b Services, you agree both to our Terms of Use and the terms and conditions of this Privacy Policy.

CLUB b Privacy Foundational Tenets:

·       You will not receive targeted third-party advertisements or targeted third-party content from us.

·       You will always maintain control of your Privacy and Permissions.

·       We do not sell your personal information to anyone.

·       You have the right to delete your account at any time.

Information We Collect

To ensure the safety and security of our users, we track how members use our site. We collect your Identity Data (which includes name or other similar identifiers) and Contact Data(which may include address, email address and telephone numbers), along with log data, usage activity, cookie data, and device/network information, to verify accounts; combat harmful conduct; detect and prevent spam, and maintain the integrity of Club b. We don’t track you to sell your data to third parties, and we don’t track you when you are not on Club b.

Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:

Financial Data, which includes credit card, debit card or other payment card details. To see more details about our collection of your Financial Data through third parties, please see the section titled “Collection of Personal Financial Information by a Payment Service” below.

Transaction Data, which includes details about payments to and from you.

Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.

Profile Data, which includes your username and password, your interests and preferences.

Usage Data, which includes information about how you use our Site and Partner Sites and advertising we serve on those sites.

We use different methods to collect information from and about you.

Directly from you: We collect information about you when you provide it to us. For example, we collect your information when you register for or subscribe to certain products or services; create a membership profile; participate in a survey; use any interactive features; participate in a community forum; or contact our customer service representatives through the messaging functionality made available to you on the Site and through the Services.

From Third Parties: We may receive information about you from third parties, such as from third party service providers that help operate, host and authenticate the Club b site.  We may share your information with these service providers on the condition that they use your private personal data only on our behalf and consistent with this Privacy Policy. If you make payments on Club b, we may share your payment information with third-party payment service providers to (i) process these payments; (ii) to detect, prevent and investigate fraud or other prohibited activities; (iii) to facilitate dispute resolution such as chargebacks or refunds; and (iv) for other purposes associated with the acceptance of credit and debit cards.

We may collect data from automated technologies or interactions: As you interact with our Site, we may automatically collect Technical Data and Usage Data about you. Some of the ways in which we or our Site may collect are further described below:

Cookies and other tracking technologies: When you access and interact with our Club b Services, we and our service providers may automatically collect certain information about those visits. For example, in order to permit your connection to the Club b Services, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. We and our service providers also may use cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology) when you visit or use the Club b Services. Third parties that support the Club b Services may do so by providing users with the ability to comment on content, allowing users to share content, customizing content based on usage, or tracking aggregate site usage statistics.

Please note that by blocking any or all cookies, you may not have access to certain features or personalization available through our Club b Services.

Collection of Personal Financial Information by a Payment Service

In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). Depending on the product or services involved, your financial information may be collected in one of two ways:

You may be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service; or

You may be making purchases directly through our Services without being routed to a Payment Service webpage, where you may provide payment information (such as payment card number and expiration date). This information is used by our Payment Service for one-time and recurring billing purposes according to the type of product ordered and the terms pertaining thereto, and to fulfill your orders. Payment card information is sent in encrypted format and is used only to send to our Payment Service, for the purposes of collecting payment for services rendered or to be rendered. We never make this information visible to anyone other than our Payment Service and never communicate it over a non-encrypted connection. The full payment card number is never seen by anyone inside our company, once entered and submitted, except by our Payment Service for the purposes of authorizing, clearing and reversing charges to your payment card. If we (or our Payment Service) have trouble processing an order, we (or our Payment Service) may use your Personal Information to contact you.

How we Use Your Information

Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below:

·       To provide our products, services and features to you, including: to process and fulfill your subscription, to send you information about your relationship or transactions with us, to measure and improve those services and features, to allow you to participate in interactive features, use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chats, and to respond to inquiries.

·       To improve the quality of our products and services

·       To personalize your experience by presenting content, products and offers tailored to you

·       Combine your information with other information relating to your use of other Real Vision products, services and websites.

·       To contact you to respond to your direct inquiries.

·       To perform specific services, you have requested

·       Where we need to comply with a legal or regulatory obligation

·       To protect the rights of Club b and others

How We Share Your Information

Club b and its affiliates may share your information with one another for the purposes described in this Privacy Policy, including for each company’s marketing purposes. Users who visit Club b’s affiliate services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. Club b is the party responsible for the management of the jointly-used Personal Information applicable to this Privacy Policy.

Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain non-affiliated third parties in the following ways:

·       To protect the rights of Club b and Real Vision and others: We may disclose your information, including situations where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Club b, and our affiliates or their employees, agents and contractors (including enforcement of our agreements and our Terms of Use); (ii) protect the safety, privacy, and security of users of our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.

·       To complete an acquisition, merger, or disposition of assets.  If Club b or Real Vision sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger, bankruptcy, or transfer of all or a material part of its business, Club b may transfer your information to the party or parties involved in the transaction as part of that transaction.

Security

Club b uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting our customer service representatives through the messaging functionality made available to you on the Site and through the Services.

Retention

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and backup. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.

Additional EU Disclosures

Our role as Data Controller and Data Processor:

Club b is the data controller of your information submitted through our Site. If you are situated in the EU and have any concerns regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact our privacy manager can be contacted here: Clubb@realvision.com

Provision Of Personal Data And Failure To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.

Legal Basis For Our Processing Of Your Personal Data

Below are the types of lawful basis that we will rely on to process your personal data:

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at Clubb@realvision.com.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.

Change Of Purpose

We will only use your personal data for the purposes for which we collected it pursuant to this Privacy Policy. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Withdrawing your Consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at Clubb@realvision.com.

Rights of EU Data Subjects

Club b would like to make sure you are fully aware of all of your data protection rights.  Every user is entitled to the following:

·         The Right To Access – You have the right to request Club b for copies of your personal data.

·         The Right To Rectification – You have the right to request that Club b correct any information you believe is inaccurate. You also have the right to request Club b to complete information you believe is incomplete.

·         The Right To Erasure – You have the right to request that Club b erase your personal data, under certain conditions.

·         The Right To Restrict Processing – You have the right to request that Club b restrict the processing of your personal data, under certain conditions.

·         The Right To Object To Processing – You have the right to object to Club b’s processing of your personal data, under certain conditions.

·         The Right To Data Portability – You have the right to request that Club b transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Email us at: Clubb@realvision.com.

You will not have to pay a fee to reasonably access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive in Club b’s reasonable opinion.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within two weeks. Occasionally it may take us longer than a two weeks if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. To exercise your rights, please contact us at Clubb@realvision.com.

Choices and Access

Your Choices Regarding Our Use and Disclosure of Your Personal Information

Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Do Not Track Signals

Opting Out Of Cookies

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Site or some of its functionality may be affected. For more information about cookies, please visit our Cookie Policy.

Opting Out Of Location Tracking

In some cases, such as when using a browser. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

Children’s Information

The Club b Services are a network of general audience sites, and are not targeted to, and do not knowingly collect Personal Information from, minors under 16 years of age. These individuals are not permitted to provide Personal Information through the Club b Services or otherwise use or access our Services without an adult supervisory account.

International Visitors

Our Site is hosted in the United States. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this Privacy Policy.  You understand that data stored in the United States and other countries may be subject to lawful requests by the courts or law enforcement authorities in such countries. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU For further details.

General Data Protection Regulation (GDPR) Compliance

We are committed to protecting the privacy and personal data of our customers and users in accordance with the General Data Protection Regulation (GDPR). We take appropriate measures to protect the security of personal data and to ensure that it is processed in accordance with the GDPR.

You have the right to access, correct, delete, or restrict the processing of your personal data, as well as the right to data portability. You also have the right to object to the processing of your personal data for certain purposes, including direct marketing.

If you have any questions or concerns about our processing of your personal data, or if you would like to exercise any of your rights under the GDPR, please contact us at Clubb@realvision.com.

We will retain your personal data for as long as necessary to provide our services and as required by law.

Analytics Software

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Our website may use Google Analytics (or similar services) to collect information about the use of our site, including the number of visitors, the websites that referred them to our site, the pages they visited on our site, and the length of their visits. This information is used to improve our website and enhance the user experience.

Google Analytics collects only the IP address assigned to you on the date you visit our website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

You can prevent Google Analytics from recognizing you on return visits to our site by disabling cookies on your browser. To opt out of Google Analytics tracking altogether, you can install the Google Analytics opt-out browser add-on.

We use the information collected by Google Analytics to better understand the usage patterns of our website, to improve the content and features offered on our site, and to make other improvements to our website. By using our site, you consent to the processing of data about you by Google Analytics in the manner and for the purposes set out above.

Updates to Privacy Policy

Club b may modify this Privacy Policy at any time in its discretion. Please look at the effective date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Club b Services. Your use of the Club b Services or your provision of Personal Information to us following these changes means that you accept the revised Privacy Policy.

Contact Us

If you have questions about this Privacy Policy, please contact us at Clubb@realvision.com through the messaging functionality made available to you on the Site and through the Services. We ask that you not disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) when contacting us, as we do not require such information from you.