CLUBCO DIRECT DATA PROTECTION AND PRIVACY POLICY

Date: January 2019

Many visitors to our website are interested in how we handle the information they provide to us. We respect your privacy and are committed to protecting your personal identifiable information.

CLUBCO Direct, Inc. is the sole owner of the information collected on our websites and on the replicated Clubco Direct websites that we provide for use by Members. We collect information from Club Members, Reward Members and visitors to the websites at different points throughout the websites.

INFORMATION COLLECTION

 

We collect two types of information: personal identifiable information that Users choose to disclose to us, and non-personal identifiable information that is collected on an aggregate and anonymous basis.

Some products and/or services may transfer you through a link to a third party site. If this is the case, you may read the “Information Collection” policy and/or “Privacy Policy” the third party sites utilize.

Personally Identifiable Information

Through your use of or visits to our websites, you may be required or requested to provide personally identifiable information to us. Personally identifiable information is any piece of information that can potentially be used to uniquely identify, contact, or locate a single person, including names, addresses, email addresses, telephone numbers, social security and tax identification numbers, and credit card information.

Registration

When you register to become an authorized reseller of our products or services, we will collect personally identifiable information. This information is securely stored and may be accessed on our website. You are assigned an identification number and select your own password – both are needed to enter the website and access your contact information.

Retail Customers may be required to register in order to purchase products directly from us (“Retail Customers”). Retail Customers will be required to provide contact information (such as name, mailing address, telephone numbers, and email address) and payment information (such as credit card or checking account information). We use this information to maintain up-to-date contact with Retail Customers, Club Members and Reward Members to process orders.

To become a Club Member, an applicant must provide biographical and contact information (such as name, mailing address, telephone numbers, and email address).

For Reward Members we also require an applicant’s Social Security Number or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS.

Product and Service Purchases

When a Retail Customer, Club Member or Reward Member purchases products or services from us through any of our websites, the purchaser must provide us with mailing and contact information as well as payment information. This information is used for billing and payment purposes and to fill orders.

Credit and Debit Card Storage

Credit and debit card information collected at registration and/or for product and/or service orders is used only to process payment for the transaction and is generally not retained on our site. You may voluntarily elect to securely store multiple cards to be used for product and/or service orders.

Downline Genealogy Reports

As a (direct sales) direct-to-consumer company, Clubco Direct provides certain information to Reward Members regarding other Reward Members, Club Members, and Retail Customers enrolled in their downline marketing organization. If you enroll as a Retail Customer, Club or Reward Member with Clubco Direct, your name, email address, and telephone number will be provided to your sponsor. No other personally identifiable information will be shared with other Reward Members. Such information is made available to Clubco Direct Reward Members subject to a confidentiality and non-disclosure covenant in the agreement that each Reward Member enters into with Clubco Direct.

INFORMATION USE


Non-Personally Identifiable Information

We store and collect various types of non-personally identifiable information on an aggregate and anonymous basis. This information may include such technical information as it pertains to your Internet Protocol (IP) address, your device operating system and browser type, cookies, and an address of a referring website or any other path you take to reach our website.

Personally identifiable information that is collected from Retail Customers, Club Members, and through Independent Reward Member, Club Member, and Retail Customer Registration, product or services purchases and/or surveys is used as described above. Clubco Direct does not share personally identifiable information except as may be necessary to process and fill orders. Clubco Direct may share aggregated information from time to time with its partners, vendors or other third parties. When Clubco Direct elects to share such aggregate information, no personally identifiable information is shared.

Aggregate Information

Aggregate information refers to information that does not, by itself, identify you as a specific individual. This information could include the Uniform Resource Locator (“URL”) of the website that referred you to our site, your IP address (a number automatically assigned to your computer whenever you surf the web), your operating system and browser type, and any search terms that you enter on our Site. Our web server aggregates this information in order to monitor the level of activity on our site, evaluate its effectiveness, and improve the content of our site to make your visit an easy and enjoyable experience.

We may collect, compile, store, publish, promote, report, or otherwise disclose or use any aggregate information, provided that such information does not personally identify you.

Profile Information

Clubco Direct stores information that it collects through cookies, log files, clear gifs, and/or third parties to create a profile of visitors to our websites (“Users”), including Club Members, Reward Members and Retail Customers. A profile is stored information that Clubco Direct keeps on individual Users that details their viewing preferences. Profile information is tied to the User’s personally identifiable information to provide offers and improve the content of the site for the User. Clubco Direct does not share profile information with other third parties.

Cookies
Cookies are pieces of data stored on a user’s computer that are tied to information about the user. Clubco Direct uses session ID cookies and persistent cookies. For session ID cookies, once users close the browser, the cookie terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.

By utilizing a cookie on a user’s computer, users do not have to enter a password more than once, thereby saving time while on the websites. This makes it easier for a user to move from site to site and to complete transactions over the Internet. If a user rejects the cookie, the user will still be able to use the site, the only drawback to this is that the user may need to enter his or her password every time he or she accesses the site.

Log Files
Like most standard website servers, Clubco Direct websites use log files. These include IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., are not linked to personally identifiable information. IP addresses are tied to personally identifiable information to enable our web-based service. We use a tracking utility that uses log files to analyze user movement.

Clear Gifs (Web Beacons/Web Bugs)

Clubco Direct employs a software technology called clear gifs (a.k.a. web beacons/web bugs), that helps Clubco Direct better manage content on the websites by informing it of what content is most effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information.

Additionally, Clubco Direct uses clear gifs in its HTML-based emails to let us know which emails recipients have opened. This allows Clubco Direct to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

 

COMMUNICATIONS FROM US

 

Special Offers and Updates

Clubco Direct sends all new Club Members and Independent Reward Members a welcome email to verify password, username, and acceptance of the Reward Member or Club Member Customer Agreement. All Club Members, Reward Members and Retail Customers will occasionally receive information on products, services, special deals, and a newsletter. Customers who have not registered with Clubco Direct and who grant permission will also receive occasional information on products, services, special deals, and similar communications.

Service Announcements

On rare occasions it is necessary to send out strictly service-related announcements. For instance, if our service is temporarily suspended for maintenance we may send Reward Members, Club Members and/or Retail Customers an email detailing the maintenance. Generally, Users may not opt-out of these communications though they can deactivate their account. These communications are not promotional in nature.

Customer Service

Clubco Direct communicates with Club Members, Reward Members and Retail Customers via email, regular mail and telephone on a regular basis to provide requested services and in regards to matters relating to their Clubco Direct orders and/or business. Clubco Direct communicates with other customers with respect to products or services purchased from Clubco Direct. Such communications may be via email, regular mail, or telephone.

SHARING

Legal Disclaimer

Though Clubco Direct makes every effort to preserve User privacy, Clubco Direct may disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or other legal process served on Clubco Direct.

 

Third Party Fulfillment

Clubco Direct uses a credit card processing company to bill Club Members, Reward Members, and Retail Customers for goods and services. These companies do not retain, share, store, or use personally identifiable information for any secondary purposes.

Service Providers

Clubco Direct partners with other third parties to provide specific services. When necessary to provide services or products to Club Members, Reward Members and Retail Customers, we share names and/or other contact information with service providers and vendors. Such third parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Business Transitions

In the event Clubco Direct goes through a business transition such as a merger, acquisition by another company, or the sale of a portion of its assets, the personal information of Club Members, Reward Members and other customers will, in most instances, be part of the assets transferred. If, as a result of the business transition, a Club Member’s, Reward Member’s, or Retail Customer’s personally identifiable information will be used in a manner different from that stated at the time of collection, the Club Member, Reward Member or Retail Customer will be given a choice consistent with our notification of changes section.

Choice

Users are always notified when their information is being collected by any outside parties. We do this so Users can make an informed choice as to whether or not they should proceed with services that require an outside party.

Links to Other Websites

Links to third party websites may be provided solely for your information and convenience or to provide additional shopping for various other goods and services through our Merchant, Product, and Service providers. Be aware that Clubco Direct is not responsible for the privacy practices of other sites. We encourage Users to be aware when they leave our site and to read the privacy statements of each website that may collect personally identifiable information. This privacy statement applies solely to information collected by Clubco Direct websites.

Security

Clubco Direct takes every precaution to protect all Users’ information. When Users submit sensitive information via Clubco Direct websites, their information is protected both online and off-line.

When the Club Member and/or Reward Member Application, Customer Registration, and/or online order forms ask Users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with SSL encryption software. While on a secure page, such as the Reward Member Application and Agreement and online order forms, the lock icon on the bottom of web browsers such as Mozilla Firefox and Microsoft Internet Explorer becomes locked, indicating the encryption is actively working.

While Clubco Direct uses SSL encryption to protect sensitive information online, the Company also does everything in our power to protect off-line User information. All User information is restricted in Clubco Direct’s offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. All employees are kept up-to-date on Company security and privacy practices. Finally, the servers that store personally identifiable information are in a secure environment.

 

MISCELLANEOUS

Changes to this Privacy Policy

Clubco Direct reserves the right to amend or change this Privacy Policy at any time at its sole discretion. It is your responsibility to remain familiar with this Privacy Policy by visiting the Privacy Policy link on our home page. When material changes or amendments are made to the Privacy Policy, we will notify all Clubco Direct Reward Members, Club Members and Retail Customers via email.

Making Changes to Your Personally Identifiable Information

Club Members, Reward Members, and Retail Customers may update personal information as necessary by logging into the Clubco Direct back office, which allows Users to access and edit registration account information. Users may also contact us at support@ClubcoDirect.com to update a User profile.

Protecting Children

Clubco Direct is committed to the safety of our underage children. Persons under the age of 18 may not enroll as Clubco Direct Reward Members or register as customers. Children under the age of 13 may not purchase products through any of our websites. We do not knowingly collect any personal information from children at this site or any of its other sites.
https://www.consumer.ftc.gov/topics/protecting-kids-online

Questions

Questions regarding this Privacy Policy should be directed to support@ClubcoDirect.com.

Effective Date

The effective date of this Privacy Policy is January 2019.

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