Summary:

1. You can review and change information about you or deactivate your account in your account settings, but we may retain certain information.
2. Consult your device settings for information about how to deactivate location-based features at any time.
3. You have the right to opt out of receiving The Women’s Social Club’s promotional messages, but you may still receive other non-promotional communications.

5.1 Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at hello@wsc.club, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

5.2 Location Information. If you initially consent to our collection of this location information through the Platform, you can subsequently stop the collection of this information at any time by changing the preferences on your computer or device. If you do so, certain features may no longer function properly.

5.3 Communications with The Women’s Social Club. We want to communicate with you in ways you want to hear from us. Examples include email, which may contain special offers and new product announcements. To the extent that you are receiving marketing communications from the Platform you may unsubscribe or opt-out of future communications as follows: If you no longer wish to receive emails you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email The Women’s Social Club sends to you, and then follow the directions to unsubscribe from email, or you can modify your preferences in your Account settings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.

5.4 Mobile Push Notifications and Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. By downloading and using our App, you may also receive promotional messages, offers, news and information about The Women’s Social Club. If you do not want to receive “in app” messages, offers, news and information, do not download or use our App.

5.5 Additional Notice to Nevada Residents. If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by hello@wsc.club.

5.6 Additional Notice to California Residents. California law requires we provide disclosures to you about what PI we collect by reference to the enumerated categories of PI set forth within California law. To address this obligation, we have identified the relevant enumerated California category for the PI described in the Information Collection section of our Privacy Policy above:

• Identifiers, including name and email address.
• User records, including password, email address, user ID.
• Internet / network information, including information about your device, browser and network and information about how you use our service and interact with us.
• Geolocation data, including general geographic information based on IP address.
• Sensory information, including profile picture.
• Professional / employment information, including the business or organization an individual represents, their title with that business or organization and information relating to their role with the business or organization, which we use to communicate with the individual about the business or organization they represent.
• Sensitive personal data, including account log-in information in combination with any required security or access code, password or credentials allowing access to an account.
• Other Personal Data, including communication preferences, inquiry information, personal information an individual permits us to see when interacting with us through social media, and personal information an individual provides us in relation to a question, request, inquiry, survey, contest or promotion.
• Inferences, including our predictions about interests and preferences and related information from the Services.

We only use or disclose sensitive information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, to comply with our legal and regulatory obligations, for detecting security incidents, fraud and other illegal actions, to ensure the safety of natural persons, to perform services on behalf of the business, or for solely internal purposes, consistent with our Privacy Policy and any other expectations we’ve set with you. We only collect and process sensitive information without the purpose of inferring characteristics about a consumer.

We do not sell any of your information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Information Usage. As described in the Information Usage section of our Privacy Policy, we use personal information for business and commercial purposes, such as fulfilling the purpose for which you provided the information, and to improve our Services and customer support.

Deidentified Information. We may at times receive, or process personal information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Information Sharing. In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:

• All of the categories of personal information we collect, explained above.

The categories of third parties to whom we disclose your personal information for a business purpose include those described in the Information Sharing section of our Privacy Policy

Sale and Sharing of Personal Information. As is common practice among companies that operate online, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies and related technologies when you visit or interact with our websites and otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, geolocation data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services.

These third parties use this personal information to serve relevant ads on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. Please see the Advertising and Analytics Services Provided by Others section of our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

We do not sell the personal information of any of our consumers or share the personal information of consumers we know to be less than 16 years of age.

Your Privacy Choices. If you are a California resident, subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Non-Discrimination / Non-Retaliation. If you are a California resident, subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• The Right to Know: The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including: (i) the categories of personal information collected; (ii) the categories of sources of the personal information; (iii) the purposes for which the personal information were collected; (iv) the categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed; (v) the categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes.
• The Right to Access & Portability: The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• The Right to Correction: The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
• The Right to Control Over Sensitive Information: The right to exercise control over our collection and processing of certain sensitive information.
• The Right to Deletion: The right to have us delete the personal information we maintain about you.
• The Right to Opt-Out of Sales or Sharing of Personal Information: The right to direct us not to “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising and targeted advertising purposes.
• The Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes.

Note that in relation to Customer Data, we act as a “service provider” and have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer. Please contact the respective customer to exercise your privacy rights with respect to Customer Data.

How to Exercise Your Privacy Rights. To exercise these privacy rights and choices, please follow the instructions below:

• How to Request That We Identify or Provide You Access to Personal Information: You may request that we identify or provide you access to your personal information twice in a 12-month period. To do so, please email us at hello@wsc.club. In response to a request to identify your personal information, we will identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months. In response to a request to access your personal information, we will produce an “Access Report” detailing the personal information we have collected and disclosed about you. This Access Report will be delivered electronically at your request.
• How to Request Deletion of Personal Information: You may request that The Women’s Social Club delete the personal information it has collected and/or maintained about you. To do so, please email hello@wsc.club. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
• How to Opt-Out of the Sale or Sharing of Personal Information:

For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other third-party tracking technologies and targeted ads, please reference our third party Platform partner’s Cookie Policy. For Non-Cookie-Based Opt-Outs: You may submit a request by emailing us at hello@wsc.club. For App-Based Opt-Outs: You may download the DAA’s CCPA App-Based Opt-Out Tool, which opts out of data processing by third parties enrolled in the DAA’s program. Please note that this opt-out is device-specific and will not be effective on your visits to the services from other devices or through the website.

Verification. Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an Account with us, we will verify your identity through existing authentication practices for the Account (e.g., login and password). If you are not a registered Website, App, or Services user, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.

Authorized Agents. In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf, or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.

Retention of Personal Information. We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Summary: 

1. The Women’s Social Club is based in and governed by U.S. law and we will be processing, transferring, and storing information in and to the U.S. and other countries.
2. We have implemented technical and organizational measures to protect your personal information. We cannot guarantee these controls will provide absolute security.
3. This Privacy Policy is periodically updated, and does not apply to third parties.

4.1 Transfer of Information to the U.S. and Other Countries. The Women’s Social Club is based in the United States. Information about you will be transferred to, and processed in, the U.S. and countries other than the country in which you are resident. 

4.2 Security. Our Platform partner, CircleCo, Inc. employs technical and organizational measures designed to protect your information that is under our control and that we process on your behalf from unauthorized access, collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. You can read more about their security measures here. 

Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.

4.3 Data Retention. We retain certain information that we collect from you while you visit or are a member of the Platform, and in certain cases where you have deleted your account, for the following business purposes:

• So you can use our Platform;
• To ensure that we do not communicate with you if you have asked us not to;
• To provide you with a refund, if entitled;
• To provide accurate accounting information to other members about the groups that they organize or administer, and associated memberships;
• To better understand the traffic to our Platform so that we can provide all members with the best possible experience;
• To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Service; and
• To comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete it or take steps to de-identify or anonymize it in accordance with applicable law.

4.4 Policy Scope. This Privacy Policy does not apply to information that you have provided or made accessible to third parties, such as other members, including group organizers and network administrators, and others with whom you may share information about yourself. Our Platform may direct you to a third party service, such as social media services, or a portion of our Platform may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platform). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our Platform or if we share information with these third parties.

Members and network administrators are directly responsible for complying with all requirements of applicable privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts, organizing and communicating with groups, or administering networks.

4.5 Revisions to this Policy. We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. Depending on the circumstances, we may provide additional notice to you of changes to this Privacy Policy, such as by sending you an email or by displaying a prominent notice on our Platform.

Summary: We do not share information about you except as described in this Privacy Policy. We may disclose personal information about you, including:

1. to members depending on how you engage with the Platform;
2. to our third-party service providers who help us to operate or improve our Platform;
3. when we work with third parties for analytics. For more information, please see our third party partner’s Cookie Policy;
4. to authorities to comply with legal obligations or requests and to protect and defend our rights and property; 
5. to an affiliate or successor entity or otherwise as part of a corporate transaction; 
6. among our businesses and affiliated companies; and
7. when you direct us to share your information. 

We may also share information in a manner that does not identify you, such as de-identified or aggregated information. Such information is not subject to this Privacy Policy.

3.1 Through Our Platform. We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. Unlike some membership Platforms, ours is always private and not visible to others off the Platform.

3.2 With Our Service Providers. We may use service providers in connection with operating and improving the Platform to assist with certain business purposes, such as payment processing, email transmission, conducting surveys or contests, data hosting, and some aspects of our technical and customer support. These service providers, which include data analytics providers (as discussed further in Section 3.4 below), may access, process, and store information about you on our behalf for the purposes we authorize, subject to confidentiality obligations.

3.3 With Our Analytics Partners. We may share information we have collected about you with others or allow others to use technologies (like cookies, web beacons, and device identifiers) that collect information about your use of the Platform and other websites and online services, to provide analytic services for The Women’s Social Club. See our third party Platform partner’s Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.

3.4 Following The Law and Protecting The Women’s Social Club. We may access, preserve, and disclose information about you to government entities and other third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, The Women’s Social Club or others. 

3.5 Social Sharing and Other Tools. The Platform may offer social sharing features and other integrated tools which let you share actions that you take on our Platform with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. The third party services' use of the information will be governed by the third parties’ privacy policies, and we do not control the third parties’ use of the shared data. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review the privacy policies of the services that provide these features.

3.6 Affiliate Sharing and Merger, Sale, or Other Asset Transfers. If The Women’s Social Club is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.

3.7 Other Situations. We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. Such information is not subject to this Privacy Policy.

Summary: We use information about you to: 

1. Operate, improve, promote, and protect The Women’s Social Club and our Platform;
2. Communicate with you; and
3. Personalize content. 

2.1 Operating Our Platform. We may use information about you described above for various business purposes related to operating our Platform, including to: 

• Provide, maintain, and improve our Platform, including to process transactions, develop new products and services (for example, including you in tests or pilots of new or revised Platform functions, such as messaging or search functionality or using information about your usage of the Platform to develop new or revised messaging or search functionality), and manage the performance of our Platform;
• Display information about you, for instance, your list of interests, which will be visible on your profile;
• Personalize the Platform, for example, to suggest content in which we think you may be interested;
• Monitor and analyze trends, usage, and activities in connection with our Platform;
• Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of The Women’s Social Club and others; to enforce compliance with our policies; and to comply with applicable law and government requests; and
• Perform accounting and administrative tasks, and enforce or manage legal claims.

2.2 Communicating With You. We may use information about you for various business purposes related to communicating with you, including to:

• Respond to your comments, questions, and requests, and provide customer service;
• Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about events on our Platform that are being held near your location, and to otherwise communicate with you in accordance with Section 2.3;
• Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and
• Send you technical notices, updates, security alerts and support, and administrative messages.

2.3 Other Uses. We may use information about you for various other business purposes, including to:

• Provide content, features, or sponsorships that match member profiles or interests 
• Facilitate contests and other promotions;
• Send you marketing communications, subject to applicable law;
• Combine with information that we collect for the purposes described in this Privacy Policy; and
• Carry out any other purposes described to you at the time that we collected the information.

2.4 Legal Basis For Processing. If you are in a jurisdiction that requires a specific legal basis for processing personal data, our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
We process information about you in order to provide our services in accordance with our Terms of Service, for example, to allow you to join groups or to display your profile to other members; to allow us to send you important service updates; and to perform a contract.

• We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
• Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Joining such groups or posting information on the Platform about these topics is entirely voluntary and, depending on the settings of the group and your profile, our legal basis for processing any sensitive information is either that you manifestly make it public or your explicit consent.
• In some cases, we may also have a legal obligation to process information about you, or may otherwise need the information to protect your vital interests or those of another person. For example, we may process information, if we believe doing so is required by, or in accordance with, applicable law, regulation, legal process, or audits.

Summary: We collect information about you when you:

1. Create an account;
2. Use the Platform;
3. Attend an event;
4. Visit our website; and
5. Communicate with us.

We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies.

1.1 Information You Provide to Us. We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include identifiers, such as your name, username, password, email address, postal address, and phone number; payment and commercial information, such as payment method data and purchases, if any; demographic information and any other personal information that you choose to provide, such as photos, choices of interests, gender, date of birth, groups, and professional or employment-related information, including your role, company, and years of experience. Certain information about yourself, such as gender and date of birth, is optional to provide. Your choice of groups is also optional, but we are required to process this information in order to administer your account, and to indicate that you are a member of the groups that you join. See Section 2 to learn how we will use the information that you provide to personalize our recommendations and other content to you.

On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions, or your sexual identity. This, and other kinds of sensitive information, is given special protection in accordance with applicable law. Posting personal or sensitive information about others without their permission is not allowed.

1.2 Information We Collect Automatically When You Use the Platform. When you use our Platform, we automatically collect internet and other electronic network activity information about you and other information, including:

1. Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration, and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
2. Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
3. Geolocation Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information, such as when you enable location services. For further information see Section 5.2. We may also collect information, such as your IP address, that can sometimes be used to approximate your location based on your device settings.
4. Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies and pixel tags (which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform. Pixel tags are electronic images that may be used in our Platform or emails, and track usage of our Platform and effectiveness of communications. You can learn more about the types of cookies our third party Platform partner uses by reading their Cookie Policy.
5. Other Information: Based on your consent, we may collect other information from your device, such as photos from your camera roll or calendar information you want to manage via the Platform.

1.3 Information We Collect From Other Sources. We may collect information about you from other sources, such as through certain features on the Platform you elect to use. We rely on these third parties to either have your consent or ensure that they are otherwise legally permitted or required to disclose your information to us. Examples include:

1. Member Content. We may receive information about you when you or another member uploads photos or posts other content to the Platform. For further details about the rights over this information available to individuals, see Section 6.
2. Current or Future Corporate Affiliates. We may receive information about you from our current or future corporate parents, subsidiaries, or affiliates.
3. Information From Other Third Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources, such as third-party publishers, advertising networks, and service providers that we use to manage ads on other sites, and other third parties as permitted by law. For more information about the data that we obtain from these providers, please contact us at hello@wsc.club.

We may analyze and make inferences from the information we collect.