Privacy Policy

Last update: November 13, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of your information when You use Our Services, as well as your privacy rights and how the law protects You.

We use your Personal Data to provide and improve the Services. By using the Services, You acknowledge the collection and use of information in accordance with this Privacy Policy. Where applicable law requires consent for a particular processing activity, we will request that consent separately.

1. Definitions

“Affiliate(s)” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

“App” means the Klubez mobile application for iOS and Android through which You may access the Services.

“CCPA” and/or “CPRA” refers to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations.

“Consumer” for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in California who is outside California for a temporary or transitory purpose.

“Cookies” are small files that are placed on your computer, mobile Device or any other Device by a website, containing the details of your browsing history on that website among its many uses.

“Device” means any device that can access the Services such as a computer, a cellphone or a tablet.

“Do Not Track or (DNT)” is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

“GDPR” refers to the E.U. General Data Protection Regulation (Regulation (EU) 2016/679) and, where applicable, the United Kingdom’s equivalent legislation (the “UK GDPR”).

“Klubez”, “We”, “Us” or “Our” (and, where used, the “Company”), refers to Klubez, Inc., a Delaware corporation.

“Personal Information and/or Personal Data” means any information relating to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

“Service Providers” means the third parties that process Personal Information on behalf of Klubez, as described in Section 4.

“Services” refers to the services described and defined in Our Terms of Service, whether accessed through the Website or the App (also referred to as the “Service”).

“Usage Data” refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

“Website”, refers to the site located at https://www.klubez.com/

“You” means the individual accessing or using the Services. Under GDPR, You can be referred to as the Data Subject or as the User as You are the individual using the Service.

2. Collecting and Using Your Personal Data - Types of Data Collected

We obtain Personal Information relating to you from various sources, as described below.

Where applicable, we indicate whether and why you must provide Us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to use our Services if that information is necessary for such purpose or if we are legally required to collect it.

You may be required to submit the following types of Personal Information to Klubez: your name, email address, username and password. If you sign in with Apple or Google, we receive your name, email address and a unique account identifier from that provider, subject to your settings with that provider.

When you play, we store your leagues, rosters, line-ups, picks, team names and results, and the messages you send in league chat. If you turn on notifications, we store a notification token for your device so we can deliver them. If you write to us for support, we keep that correspondence. Your username, team names, rosters, line-ups, picks, results and league chat messages are visible to the other members of the leagues you join.

Usage Data

Usage Data is collected automatically when using Our Services. Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that You visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever You visit our Services or when You access the Services by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Services. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.
Web Beacons. Certain sections of our 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 the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and/or App and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website and/or App.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website and/or App, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website and/or App.

Tracking and Performance Cookies

Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and/or App and how users use the Website and/or App. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website and/or App. We may also use these Cookies to test new pages, features or new functionality of the Website and/or App to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please contact Us at privacy@klubez.com. You can also control push notifications and device permissions at any time through your device settings.

3. Use of Your Personal Information

We may use your Personal Information to:

Create and manage your account, provide our Services, and respond to your inquiries;
Manage account authentication such as two-factor authentication;
Communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, including by periodically emailing you service-related announcements;
Tailor our Services (e.g., We may use Cookies and similar technologies to remember your preferences);
Publish your content, comments or messages on social media platforms;
Aggregate your Personal Information for analytical purposes;
Provide customer support;
Operate, evaluate and improve our business (including by developing new products and Services; managing our communications; determining the effectiveness of our advertising; analyzing how the Services are being accessed and used; tracking performance of the Services; data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience, debugging the Services; facilitating the use of our Services);
Send you marketing communications about products, services, offers, programs and promotions of Klubez and its Affiliates, subject to your communication preferences and applicable law;
Ensure the security of our Services;
Manage our customer, service provider and partner relationships;
Enforce our agreements related to our Services and our other legal rights; and
Comply with applicable legal requirements, industry standards and our policies.

For further information under GDPR provisions, please see Exhibit I.

If You are a California resident, please see Exhibit II.

We may disclose your Personal Information with:

Service Providers: We engage certain trusted third parties to perform functions and provide services to Us, including hosting and maintenance, analytics and data insights, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide Services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
Compliance with Laws and Law Enforcement: Klubez may cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, We may disclose any Personal Information about You to government or law enforcement officials or private parties as We believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Klubez or a third party, to protect Klubez against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and any equipment used to make the Services available, or to comply with the law.
Business Transfers: Klubez may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. In such event, We will require the recipient to process your Personal Information consistently with this Privacy Policy, and We will notify You if the recipient’s planned processing of your Personal Information differs materially from that set forth in this Privacy Policy.
No sale, no targeted advertising, no data brokers: We do not sell your personal information, share it for targeted advertising, or give it to data brokers.
Other Users: Your username, team names, rosters, line-ups, picks, results and league chat messages are shared with the other members of the leagues you join.
Aggregated or de-identified information: We may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify you — for example, how many people played in a tournament, or which clubs were chosen most often — with sponsors, partners and the public. We do not attempt to re-identify such information, and we require those who receive de-identified information from us to do the same.
With Your Consent: We may disclose your Personal Information for any other purpose with your consent.
Sponsors, partners and links: The Services may show content from sponsors and partners — for example, a tournament or a weekly feature presented by a brand — and links to third-party websites and stores. What you see depends on where you are in the Services, not on a profile of you, and we do not give sponsors or partners your personal information. Some links are commissioned: if you buy or subscribe after following one, Klubez may receive a payment from that company.
Advertising: The Services may show advertisements delivered by advertising partners. These advertisements are not personalized — they are not chosen using a profile of you — and we do not use them to track you across other companies’ apps or websites. To deliver an advertisement, the advertising partner receives technical information from your device, such as its IP address, type and operating system. Advertising partners receive the technical information described here to deliver and measure non-personalized advertisements, not to select advertisements based on your activity across other companies’ services.

List of other third-party services We may use:

Amazon Web Services
Vercel
Supabase
PostHog
Expo (notification delivery and app updates)
Apple and Google (sign-in and notification delivery)
Sentry (crash reporting)
Microsoft (email)
Resend (email delivery)
Google Fonts (website fonts)

5. How We Protect Your Personal Information

We employ administrative, physical and electronic measures designed to appropriately protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on our Website and/or App in the most expedient time possible and without unreasonable delay.

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which We process it, unless We are required by law to keep this information for a longer period. In general, We retain your account information for as long as your account is active. When you delete your account, We delete or anonymize your Personal Information within a reasonable period, except for information We must retain to comply with legal obligations, resolve disputes, prevent fraud or abuse, or enforce our agreements, and residual copies in backups, which are overwritten in the ordinary course.

Children’s Privacy

Our Service does not address anyone under the age of 13, 14 if you are located in China, 15 if you are located in Japan and 16 if you are located in the European Union. We do not knowingly collect personally identifiable information from anyone under the age of 13, 14 if you are located in China, 15 if you are located in Japan and 16 if you are located in the European Union. If You are a parent or guardian and You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13, 14 if you are located in China, 15 if you are located in Japan and 16 if you are located in the European Union, We will take steps to remove that information from Our servers.

6. Your Rights and Choices

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Services.

We aim to comply with applicable data protection laws worldwide, including but not limited to GDPR (EU), UK GDPR, CCPA/CPRA (California, USA), LGPD (Brazil), COPPA (USA), and PIPL (China). Where local law imposes different or additional obligations, we will comply with those obligations to the extent they apply to your use of the Services.

You may update, amend, or delete your information at any time by signing in to your account, if you have one, and visiting the account settings section that allows you to manage your Personal Information. You may also contact Us to request access to, correct, or delete any Personal Information that You have provided to Us by email at privacy@klubez.com.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

For further information under GDPR provisions, please see Exhibit I.

If You are a California resident, please see Exhibit II.

Marketing Communications and Unsubscribe Rights

We may send you marketing emails or newsletters if you have chosen to receive them. You can opt out of these communications at any time by:

Clicking the “unsubscribe” link included in each email, or
Contacting us at privacy@klubez.com

We will process your request without undue delay and, in any case, within the time period required by applicable law (e.g., within 10 business days under U.S. CAN-SPAM rules).

Please note that even if you unsubscribe from marketing emails, we may still send you non-promotional messages related to your account, security, or transactions.

Push Notifications

You can turn off push notifications at any time through your device settings.

7. Data Transfers

Klubez is based in the United States. Personal Information that We collect may be transferred to, and stored at, any of our Affiliates, partners or service providers which may be inside or outside the European Economic Area (“EEA”), the United Kingdom and Switzerland, including the United States. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. When We transfer Personal Information from the EEA, the United Kingdom or Switzerland to a country that has not been recognized as providing an adequate level of protection. Where required, we use an applicable lawful transfer mechanism for transfers of Personal Information outside your jurisdiction. Contact privacy@klubez.com for information about the mechanism relevant to your data. You may request a copy of the relevant safeguards by contacting Us.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. We will notify you of any modifications to our Privacy Policy by posting the new Privacy Policy on Our Website and/or App and indicating the date of the latest revision. You are advised to consult this Privacy Policy regularly for any changes.

In the event that the modifications materially alter your rights or obligations hereunder, We will make reasonable efforts to notify you of the change. For example, We may send a message to your email address or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

9. How To Contact Us

If you have any questions or comments regarding this Privacy Policy, or if you would like to exercise your rights to your Personal Information, you may contact Us via email at privacy@klubez.com.

By mail: Klubez, Inc., 169 Madison Ave, STE 38087, New York, NY 10016.

We may process Personal Data under the following conditions:

Consent: You have given your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee You can exercise your rights.

You have the right under this Privacy Policy, and by law if You are located in the EEA or the United Kingdom, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes You want to object to our processing of your Personal Data on this ground. You also have the right to object where We are processing your Personal Data for direct marketing purposes.

Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If You withdraw your consent, We may not be able to provide You with access to certain specific functionalities of the Service. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.

You may exercise your rights of access, rectification, erasure, restriction, portability and objection by contacting Us. Please note that we may ask You to verify your identity before responding to such requests. If You make a request, We will respond within one (1) month of receipt, which may be extended by two (2) further months where necessary, taking into account the complexity and number of requests, in which case We will inform You of the extension.

You have the right to complain to a Data Protection Authority about Our collection and use of your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA. If You are in the United Kingdom, You may contact the Information Commissioner’s Office (ICO).

Exhibit II — CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Information were in fact collected by Us but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if You provided such Personal Information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.
Collected: No.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.
Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.
Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.
Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.

Category K: Inferences drawn from other Personal Information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.

Category L: Sensitive Personal Information.

Examples: Account login and password information, precise geolocation data.
Collected: Yes.

Under CCPA/CPRA, Personal Information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

Information excluded from the CCPA/CPRA’s scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from your purchases on our Service.

Indirectly from You. For example, from observing your activity on our Service.

Automatically from You. For example, through cookies We or our Service Providers set on your Device as You navigate through our Service.

From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that We use to provide the Service to You. We also receive information from Apple or Google when You choose to sign in using those services.

Use of Personal Information

We may use or disclose Personal Information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

To operate our Service and provide You with Our Service.
To provide You with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.
To fulfill or meet the reason You provided the information. For example, if You share your contact information to ask a question about our Service, We will use that Personal Information to respond to your inquiry.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting your Personal Information or as otherwise set forth in the CCPA/CPRA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the Section 3 (“Use of Your Personal Information”) of this Privacy Policy.

If We decide to collect additional categories of Personal Information or use the Personal Information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose Personal Information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Disclosure to service providers.

We disclose your Personal Information only to our Service Providers and to third-party vendors to whom You or your agents authorize Us to disclose your Personal Information in connection with products or services We provide to You.

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing Personal Information, but not necessarily a monetary benefit.

We do not sell Personal Information, and we have not sold or shared it in the last twelve (12) months.

Sale of Personal Information of Minors

We do not knowingly collect Personal Information from minors through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell or share the personal information of anyone, including consumers we know are minors.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with Personal Information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their Personal Information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Personal Information. Once We receive and confirm your request, we will disclose to You:

The categories of Personal Information We collected about You.
The categories of sources for the Personal Information We collected about You.
Our business or commercial purposes for collecting or selling that Personal Information.
The categories of third parties with whom We share that Personal Information.
The specific pieces of Personal Information We collected about You.
If we sold your Personal Information or disclosed your Personal Information for a business purpose, We will disclose to You:
- The categories of Personal Information categories sold
- The categories of Personal Information categories disclosed

The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell or share your Personal Information. To submit an opt-out request, please contact Us. As described below, We do not currently sell or share Personal Information.

The right to correct Personal Data. You have the right to correct or rectify any inaccurate Personal Information about You that We collected. Once We receive and confirm your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your Personal Information, unless an exception applies.

The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive Personal Information We collected about You, unless an exception applies. To submit, please contact Us.

The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm your request, We will delete (and direct Our Service Providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for Us or Our Service Providers to:

Complete the transaction for which We collected the Personal Information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:

Denying goods or services to You.
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
Providing a different level or quality of goods or services to You.
Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell My Personal Information” section and “Limit the Use or Disclosure of My Sensitive Personal Information” section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us by email at privacy@klubez.com.

Only You, or an authorized agent (a natural person, or a business entity registered with the California Secretary of State) that You authorize to act on your behalf, may make a verifiable request related to your Personal Information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative
Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide You with the required information if We cannot:

Verify your identity or authority to make the request.
And confirm that the Personal Information relates to You.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Unless You request otherwise, any disclosures We provide will cover the 12-month period preceding Our receipt of the verifiable request. You may request information collected beyond that period, unless providing it would prove impossible or involve a disproportionate effort.

For data portability requests, We will select a format to provide your Personal Information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale or sharing of your Personal Information.

Because we do not sell or share personal information, there is nothing to opt-out of today. If that ever changes, we will say so here before it starts.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of your sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive Personal Information in ways that are necessary to provide the Service. For more information on how We use your Personal Information, please see the Section 3 (“Use of Your Personal Information”) of this Privacy Policy or contact us.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If You are visiting such websites, You can set Your preferences in your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798.83 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

Vía email: privacy@klubez.com