PRIVACY POLICY

This Privacy Policy was last updated on December 17, 2019.

We, The Cluber and our corporate affiliates (“Cluber“, “we” or “us“), are committed to protecting and respecting your privacy. We are the company responsible for the collection, use, and disclosure of your personal information under this Privacy Policy. We believe in transparency and want you to feel comfortable using our platform, and we are committed to being upfront about our privacy practices.

1. Introduction

• Scope of this Privacy Policy

This Privacy Policy explains the information we collect from you when you access and use the Cluber family of websites (each, a “Site” and collectively, the “Site“), as well as our platforms, widgets, analytics tools, and other technical applications that we may provide either through our Sites or through third-party websites or other products and services provided by us (which, together, are referred to as the “Services”), how we use and disclose such information. We also wish to make sure that you are aware of the options available to you when you access and use our Services.

• Contact Us

If you have any questions about this Privacy Policy, please contact us at:

The Cluber

Email address: theclubermagazine@gmail.com

Phone: (786) 721-3001

Postal address: 16900 N Bay rd, Sunny Isles Beach, FL 33160.

• Third-Party Links

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect information about you. We do not control these third-party services and are not responsible for their privacy, information, or other practices. We encourage you to read the privacy policy of every website or other online service that you visit or use.

2. Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. If you choose to contact us by using the forms provided on our Site, you may choose to provide Personal Information to us, such as your full name, email address, phone number, job title, and company. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3. Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes, including to:

• Provide the functionality of the Services and fulfill your requests.
  • To respond to your inquiries and fulfill your requests, such as when you contact us by using the forms provided on our Site.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Aggregate and/or anonymize Personal Information.

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other information for our use, which we may use and disclose for any purpose.

• Accomplish our business purposes.

• For data analysis, for example, to improve the efficiency of our Services;

• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;

• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

• For developing new products and services;

• For enhancing, improving, or modifying our current products and services;

• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

4. Disclosure of Personal Information

Your Personal Information will be disclosed:

• To our affiliates for the purposes described in this Privacy Policy, including to Songo Media Inc., a Delaware corporation.

• To our third-party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, auditing, and other services.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations, which can include laws outside your country of residence.

• To cooperate with public and government authorities, to respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.

• To cooperate with law enforcement, such as when we respond to law enforcement requests and orders or provide information we believe is important, including to law enforcement outside your country of residence.

• For other legal reasons, such as to enforce our terms and conditions and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

5. Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

6. Cookies and Tracking

When you use or interact with our Services, we or our service providers automatically collect certain information, such as your browser and device information, IP address, and information collected through cookies and similar technologies. We use this information to ensure that the Services function properly, for security purposes, to facilitate navigation, to display information more effectively, to understand and measure how the Services are used, to improve and resolve questions regarding the Services, to resolve When visiting our Site for the first time, you will be prompted to provide consent for our use of cookies questions about them, and to measure the effectiveness of our marketing campaigns.

To learn more about how we use cookies, or to opt out of the collection and use of cookies, please see our Cookie Notice, which is incorporated by reference into this Privacy Policy.

We do not currently respond to browser do-not-track signals.

7. Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

8. Retention Period

We retain aggregated or anonymous information, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9. Information Security

We have put in place security measures designed to prevent Personal Information from being accidentally lost or acquired, used, accessed, altered, or disclosed in an unauthorized way. Please keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Personal Information may have been compromised during, or as a result of, your use of the Services), please immediately notify us in accordance with the “Contact Us” section above.

10. Protection of Children’s Privacy

We are concerned about the privacy and safety of children when they use the internet. Our Services are not directed to children under eighteen (18).

We will never knowingly request Personal Information online from anyone under the age of 18 without prior verifiable parental consent. Our Services are general audience sites and are not targeted to or intended for use by children. However, if we learn that we have received information from a child under the age of 18 without parental consent, we will delete that information from our database.

11. Choices and Access

If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us at theclubermagazine@gmail.com or 16900 N Bay rd, Sunny Isles Beach, FL 33160. We will respond to your request consistent with applicable law.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

12. Changes to Our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Your use of the Services following these changes means that you accept the revised Privacy Policy.

13. Additional Information Regarding the European Economic Area

If you are located within the European Economic Area, you may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

14. Additional Information for California Consumers

The following portion of this Privacy Policy applies solely to visitors, users, and others who reside in the State of California. This portion of our Privacy Policy is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice if capitalized herein.

Information We Collect

We may collect certain 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. In particular, as indicated below, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’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.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly and indirectly from your activity on our Sites, including information our servers automatically collect and information collected from cookies on our site as described in our Cookie Notice.
• From third-parties that interact with us or our Sites.
• Publicly available data bases.
• From social networks, such as Facebook, Instagram or Twitter, if you use a social network login to access our services or Sites.
• Joint marketing partners.
• From your mobile device, such as your mobile device ID, model, and manufacturer, and information about the location of your device.
• When you apply for a job through our Sites.
• When you register on our Sites.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• Analyze the use and performance of our Sites and services.
• Identify you when you visit our Sites and as you navigate our Sites.
• Display advertisements that will be relevant to you.
• Share your personal data with third parties who process your data on our behalf when they provide certain services to us, such as data analytics, ad networks, research, marketing, email delivery, hosting services, customer service and legal and financial services.
• Share your personal data with third parties who use it for their own purposes if you have provided consent to do so.
• Monitor and analyze usage and trends to improve your experience with the Sites.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Sites to you.
• Store your preferences including language, past searches, location and preferences.
• To fulfill or meet the reason for which the information is provided.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To improve our Sites and presentation of content to you.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.
• Recommend additional content to you from our Site or from other Sites within our network of Sites.
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• As described to you when collecting your personal information or as otherwise set forth in this Policy or the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business 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.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category K. Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Third party service providers who may process your data on our behalf when they provide certain services to us, such as data analytics, ad networks, research, marketing, email delivery, hosting services, customer service and legal and financial services.
• Third-party partners who may deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we or they provide to you.
• Our affiliates.

The information categories set forth above may have been shared with certain trusted third parties to perform functions and provide services to us, including performance monitoring, site development, customer relationship, direct marketing, advertising, and related services. We share such information only to the extent necessary to perform these functions and provide such services.

In the preceding twelve (12) months, we have not sold any personal information except as set forth above.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Notice of Right to Opt Out of Sale of Personal Information

You have the right to opt out of collection and sharing by us of certain of the personal information listed above. Please click on the “Do Not Sell My Personal Information” link (the “Link”) found in the footer of our Sites. In the pop up that appears when you click the Link, the toggle next to “Personalized Advertisements” will be toggled to “off”. If you click the “Confirm” button, we will no longer share your personal information with our third-party partners and service providers that may otherwise use such information to deliver targeted, personalized or interest-based advertisements. To learn more about interest-based advertising across our Sites and additional opt-out choices, please see our Cookie Policy and visit one or more industry opt-out links (e.g., http://optout.aboutads.info/#/, http://optout.networkadvertising.org/#, and http://www.aboutads.info/appchoices). Please note that you may need to refresh your browser or move to a new page for the interest-based advertising to disappear, although you may continue to see non-interest-based advertisements. Please also be aware that if you opt out through the Link of the sharing of your information for CCPA purposes but do not opt out of interest-based advertising more generally you may still receive ads tailored to your interests based upon: (i) information not shared by us; (ii) information shared to downstream participants at least ninety (90) days before your opt out; or (iii) information sold to third-party advertisers by other sources from which you have not opted out.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer 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 purpose 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 or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, or deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us toll-free at (786) 721-3001
• Emailing us at theclubermagazine@gmail.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will make every effort to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing. The total period will not exceed 90 days. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Call us toll-free at (786) 721-3001

Email us at theclubermagazine@gmail.com

Send us mail at:

The Cluber

16900 N Bay rd

Sunny Isles Beach, FL 33160

COOKIE NOTICE

Last revised: December 9, 2019

This Cookie Notice (“Notice”) explains more about how The Cluber and its affiliates (“Cluber”, “we”, “us” or “our”) and our authorized service providers, may use cookies, web beacons, and other similar technologies (collectively “cookies”) on the Cluber of websites (the “Sites”), as well as your choices related to such use.

We may change this Notice at any time. Please refer to the top of this page for the date this Notice was last revised. Any changes in this Notice will become effective when we post the revised Notice to this Site. This Notice is incorporated in and part of our Privacy Policy.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that a web server transmits to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie will be stored by a web browser and remain valid until its expiration date, unless it is deleted by the user, while a session cookie will expire when the web browser is closed at the end of the user session.

Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. Cookies enable a website to remember your actions and preferences over a period of time, so you don’t have to repetitively enter certain information, perform certain action or configure certain aspects of a website whenever you return to the website or browse from one page to another. More information about cookies and how they work is available at www.allaboutcookies.org.

Cookies that we use

We use cookies to:

• Identify you when you visit our Site and as you navigate our Site
• Analyze the use and performance of our Site and services
• Display advertisements that will be relevant to you
• Store your preferences in relation to the use of cookies more generally

• Maintain your session
• Remember your language and origin settings
• Remember your past searches on our Sites
• Remember your location
• Remember your preferences

Cookies used by our service providers

Analytics/Performance Cookies: Our service providers use cookies that may be stored on your computer when you visit our Site.

Google Analytics. We use Google Analytics. Google Analytics gathers information about the use of our Site by means of cookies. This information is used to create reports about the use of our Site. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy notice at https://policies.google.com/privacy. If you want to opt-out of being tracked by Google Analytics, visit the Google Analytics Opt-out page at https://tools.google.com/dlpage/gaoptout and install the add-on for your browser.

Facebook Analytics. We use a Facebook pixel on our Site. Using the pixel, Facebook collects information about the users and use of our Site. The information is used to personalize Facebook advertisements and to analyze the use of our Site. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217, and you may opt out from tracking by the Facebook pixel under https://www.facebook.com/settings?tab=ads.

Other Third-Party Cookies. We also use other third-party service providers, such as Comscore, Taboola, Quantcast, and Outbrain, which may use cookies for interest-based advertising and behavior analytics. Specifically, you may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/, http://optout.networkadvertising.org/#/ and www.youronlinechoices.eu.

Managing cookies

Most browsers also allow you to refuse to accept cookies and to delete cookies. You can normally change your browser settings within the ‘options’ or ‘preferences’ menu for your browser. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain cookies, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers.