Privacy Policy

Introduction

In the Clurb, Inc. ("Clurb," "we," "our," or "us") provides a platform through which people can create, operate, discover, and join membership clubs, communicate with club communities, host and attend events, and pay or receive dues and other fees. This Privacy Policy explains how we collect, use, disclose, retain, and otherwise process personal information through our websites, mobile applications, and related services (collectively, the "Platform").

This Policy applies when Clurb determines the purposes and means of processing personal information. A club organizer (a "Curator") may separately determine how to use information obtained from or about club members. In that situation, the Curator is independently responsible for its privacy practices. Section 14 explains this distinction.

This Policy does not apply to third-party websites, services, or payment products governed by their own privacy notices. Please review this Policy before using the Platform. If you are a California resident, see Section 15.

1. Personal Information We Collect

The information we collect depends on how you use the Platform, the features you enable, and the choices you make.

Please do not provide sensitive information through posts, profiles, or support channels unless it is necessary and appropriate. Information posted to community features may be seen, copied, or reshared by others with access to that community.

2. Payments and Third-Party Payment Services

Payments and payouts are currently facilitated by Stripe, Inc. Stripe may collect payment-card or bank information, billing details, transaction information, device information, and fraud-prevention or identity-verification information under its own privacy policy. Clurb does not intend to store full payment-card numbers on its servers, but receives transaction, customer, payment, payout, dispute, and verification information needed to operate the Platform. Stripe’s privacy policy is available at https://stripe.com/privacy. If Clurb adds or replaces a payment provider, the applicable provider’s notice will govern information it collects directly.

3. How and Why We Use Personal Information

• Provide, administer, and personalize accounts, clubs, memberships, events, community features, discovery, recommendations, and leaderboards.
• Process dues, purchases, refunds, disputes, taxes, identity verification, and Curator payouts.
• Deliver invitations and referrals requested by users, and record invitation status.
• Communicate about accounts, security, transactions, memberships, events, renewals, policy changes, and support.
• Send marketing or promotional communications as permitted by law and honor opt-out choices.
• Analyze performance and use, troubleshoot, test, develop, and improve the Platform.
• Protect users and the Platform; authenticate accounts; detect, investigate, and prevent fraud, spam, abuse, security incidents, and unlawful activity.
• Moderate content and enforce our agreements, policies, and community standards.
• Comply with law, legal process, tax and accounting requirements, and valid requests from authorities; establish, exercise, or defend legal claims.
• Carry out a corporate transaction and other purposes disclosed when information is collected or with your consent.

4. Cookies, Similar Technologies, and Analytics

We and providers acting for us may use cookies, local storage, pixels, software development kits, and similar technologies to authenticate users, maintain sessions, remember preferences, measure use and performance, prevent fraud, and improve the Platform. The specific technologies and providers may change as the Platform develops.

You can control browser cookies through your browser settings and mobile permissions through device settings. Blocking technologies may cause some Platform features not to function. Where required, we provide additional choices through a cookie or privacy-control interface. We do not currently use personal information for cross-context behavioral advertising, sell personal information, or request Apple’s permission to track activity across other companies’ apps or websites. If these practices change, we will update this Policy and provide any legally required notice and choice before applying the change.

We honor browser-based opt-out preference signals, including Global Privacy Control, where legally required and technically applicable. "Do Not Track" is a separate signal for which no generally accepted response standard currently applies.

5. Artificial Intelligence and Automated Features

Clurb may use artificial intelligence or machine-learning tools to recommend clubs or events, improve search, moderate content, detect spam or fraud, assist support, or help users draft content. Depending on the feature, inputs and outputs may be processed by a service provider operating under contractual restrictions. Do not submit confidential, sensitive, or third-party personal information to an AI-assisted feature unless the feature requests it and you are authorized to provide it.

Clurb does not use private club content to train a publicly available, general-purpose AI model. We may use content and feedback to operate, secure, evaluate, and improve Clurb features, including models dedicated to Clurb, subject to applicable law and any in-product disclosures or controls. Users must review AI-assisted output before relying on or publishing it. Clurb does not currently use automated processing to make decisions that produce legal or similarly significant effects concerning users.

6. How We Disclose Personal Information

We may disclose the categories described in Section 1 to the following recipients for the purposes described in this Policy:

• Curators and club participants. Curators receive information reasonably needed to operate their clubs, which may include profile and contact information, membership and payment status, RSVPs, check-ins, and communications. Profiles, posts, photos, event activity, and leaderboard information may be visible to participants according to club and Platform settings.
• Vendors and service providers. Hosting, database, payment, identity-verification, communications, push-notification, analytics, customer-support, content-moderation, AI, fraud-prevention, security, and professional-service providers may process information for us under appropriate restrictions.
• Payment and transaction participants. Payment processors, financial institutions, networks, and counterparties receive information needed to complete, administer, or dispute a transaction.
• At your direction. We disclose information when you invite someone, share content, connect a service, authorize a Curator or third party, or otherwise direct us.
• Corporate transaction recipients. Information may be disclosed in due diligence or transferred in a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate safeguards.
• Authorities and others for legal, safety, and integrity purposes. We may disclose information when we reasonably believe disclosure is required or permitted by law, necessary to protect rights, safety, and property, or appropriate to investigate fraud, abuse, or violations.
• Affiliates. Current or future corporate affiliates may process information consistently with this Policy.

We may disclose aggregated or deidentified information that cannot reasonably be used to identify you. We maintain and use deidentified information in deidentified form and do not attempt to reidentify it except as permitted by law.

7. Community Visibility and Public Features

Club content is ordinarily available to the relevant Curator and club participants, subject to applicable settings. Some club pages, profiles, event listings, or user profiles may be publicly discoverable if the feature or settings indicate that they are public. Recipients may save, copy, or reshare information. Review the audience and settings before posting. Removing content from Clurb does not remove copies retained by other users or third parties.

8. Communications and Mobile Permissions

You can unsubscribe from marketing email by using the link in the message and can adjust push notifications through the Platform or device settings. You may still receive non-promotional messages such as receipts, security notices, support responses, legal notices, and membership or renewal communications. For text messages, follow the opt-out instructions in the message. Message and data rates may apply.

The mobile app may request access to contacts (to select invitees), photos or camera (to upload profile or event content), and notifications (for communications you enable). Permission is optional and can be changed in device settings. When you invite someone, you represent that you are authorized to provide the selected contact information and request the communication.

9. Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including to provide the Platform, maintain business and transaction records, comply with law, prevent fraud and abuse, resolve disputes, and enforce agreements. Retention depends on the type of information, the sensitivity and risk of harm, the reason for processing, user and Curator choices, backup cycles, and legal requirements.

10. Security

We use administrative, technical, and physical safeguards designed to protect personal information, which may include encryption in transit, access controls, authentication, monitoring, and security logging. No system is completely secure. You are responsible for maintaining the confidentiality of your credentials and promptly notifying us of suspected unauthorized account use.

11. International Processing

Clurb is based in the United States. We and our providers may process information in the United States and other countries whose laws may differ from those where you live. Where required, we use an approved transfer mechanism or another lawful safeguard. EEA, Swiss, and U.K. users may contact us to request information about applicable safeguards.

12. Your Choices and Privacy Rights

Depending on your location and subject to exceptions, you may have the right to access, correct, delete, or obtain a portable copy of personal information; object to or restrict certain processing; withdraw consent; opt out of sale, sharing, targeted advertising, profiling, or certain automated decisions; and appeal a denied request. Withdrawing consent does not affect processing already completed.

Submit a request through Profile > Settings > Privacy, if available, or email privacy@clurbs.com. We may verify your identity by matching information you provide with account records and may ask you to confirm control of an email address, phone number, or account. We will use request information only to verify and respond to the request. Authorized agents must provide legally sufficient proof of authority; we may also verify the consumer directly where permitted. We will not unlawfully discriminate or retaliate because you exercise a privacy right.

If we deny an appealable request, you may appeal by replying to our response or emailing privacy@clurbs.com with "Privacy Appeal" in the subject line. We will respond within the period required by applicable law and explain any additional complaint options.

13. Account Deletion

You may initiate account deletion in the app through Profile > Settings > Delete Account, if available, or email support@clurbs.com from the address associated with your account. Deletion removes or deidentifies account information from active systems within a reasonable period, generally 30 days, except information retained for transactions, legal compliance, security, fraud prevention, dispute resolution, or enforcement. Backup deletion follows ordinary cycles. Club posts or event records may remain without your profile attribution where needed to preserve community or transaction context, and copies held by other users or Curators are outside Clurb’s control.

14. Curators and Club-Directed Processing

A Curator may independently collect information, choose membership requirements, communicate with members, export or maintain club records, or use information outside the Platform. For those activities, the Curator may be an independent business or controller and should provide any notice and choices required by law. Direct questions about a Curator’s independent practices to that Curator.

When Clurb processes personal information solely under a Curator’s documented instructions, Clurb may act as the Curator’s service provider or processor. For account administration, Platform security, billing, product improvement, legal compliance, and other purposes Clurb determines, Clurb acts as a business or controller. A request to Clurb may not delete information independently controlled by a Curator; where appropriate, we will explain how to contact the Curator.

15. California Privacy Notice

This section supplements the Policy for California residents. It uses terms defined in the California Consumer Privacy Act, as amended ("CCPA"). It applies only to information and entities covered by the CCPA.

Collection, Use, and Disclosure in the Preceding 12 Months

The CCPA categories collected, sources, purposes, and recipients are described more fully in Sections 1, 3, and 6.

Retention criteria are in Section 9. Clurb does not use or disclose sensitive personal information for purposes that require offering a right to limit under the CCPA.

Sale, Sharing, and Targeted Advertising

Clurb does not currently sell personal information or share it for cross-context behavioral advertising, as those terms are defined by the CCPA, and has not done so in the preceding 12 months. Clurb does not knowingly sell or share personal information of consumers under 16. If these practices change, we will provide legally required notice and opt-out methods, including recognition of applicable opt-out preference signals.

California Rights and Requests

Subject to legal limitations, California residents may request to know the categories and specific pieces of personal information collected; the sources, purposes, and recipients; access or portability; correction; deletion; and information about sale, sharing, or disclosure. Residents also may opt out of sale or sharing and limit certain uses of sensitive personal information where those practices occur. Clurb will not discriminate for exercising CCPA rights.

Use the methods in Section 12. We will confirm receipt and respond within the periods required by law, generally acknowledging a request to know, delete, or correct within 10 business days and responding within 45 calendar days, subject to a permitted extension. Requests to know specific pieces require heightened verification. We may deny or limit a request where an exception applies and will explain our decision.

Direct Marketing and Content Removal

California Civil Code Section 1798.83 permits certain residents to request information about disclosures to third parties for their direct-marketing purposes. Clurb does not disclose personal information to third parties for their own direct marketing as contemplated by that law. California residents under 18 who are registered users may request removal of content they posted by emailing privacy@clurbs.com. Removal may be limited by law and does not ensure removal of copies held or reposted by others.

16. Other U.S. State Privacy Rights

Residents of states with comprehensive privacy laws may have rights described in Section 12, subject to applicable scope, definitions, and exceptions. Where applicable, you may opt out of targeted advertising, sale, or certain profiling through the privacy settings or by emailing privacy@clurbs.com. Because Clurb does not currently engage in those practices as defined by applicable state laws, an opt-out may not change current processing. You may appeal a denial as described in Section 12.

17. EEA, Switzerland, and United Kingdom

Where applicable, Clurb relies on the following legal bases: performance of a contract (providing requested Platform features); legitimate interests (operating, improving, securing, marketing, and protecting the Platform and users, balanced against your rights); consent (such as optional device access or certain marketing); and legal obligations. Information required to provide an account or transaction must be supplied if you wish to use that feature; other information is optional.

You may have rights of access, rectification, erasure, restriction, portability, objection, and withdrawal of consent, and the right to complain to your local supervisory authority. You may object to processing based on legitimate interests, including direct marketing. Clurb is the controller for processing it determines; contact details appear in Section 21. If legally required, Clurb will appoint and identify an EEA or U.K. representative or data protection officer in this Policy or a supplemental notice.

18. Children’s Privacy

The Platform is intended only for individuals age 18 or older and is not directed to children. We do not knowingly collect personal information online from a child under 13. If we learn that we collected such information without legally sufficient authorization, we will delete it as required. Contact privacy@clurbs.com if you believe a child has provided personal information. Curators may not invite, enroll, or create an account for a person under 18 unless Clurb expressly offers an authorized feature with an appropriate notice and consent process.

19. Third-Party Services

The Platform may link to or integrate with third-party services, including payment providers, Curator sites, social media, and connected services. Their privacy practices are governed by their own notices. A link or integration does not mean Clurb controls or endorses those practices.

20. Changes to This Policy

We may update this Policy to reflect changes in the Platform, our practices, or law. We will post the revised Policy and update the date above. If changes are material, we will provide additional notice as required, such as through the Platform or by email. We will obtain consent before applying a change where required by law.

21. Contact Us

Questions or privacy requests may be directed to:

In the Clurb, Inc.Attn: PrivacyPO Box 1173Newport Beach, CA 92659Email: phil@clurbs.comSupport: support@clurbs.com