Effective February 2020
III. INFORMATION WE COLLECT
We cannot help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet so we collect that information. We also collect information generated as you use our Club Soda Services, for example access logs, as well as information from third parties, like when you access our Club Soda Services through a social media account.
We also collect information you choose to give us, like when you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.
When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our collection, retention and processing of that information to provide the Services to you.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the Club Soda Services.
IV. INFORMATION WE RECEIVE FROM OTHERS
In addition to the information you provide us directly, we receive information about you from others, including:
Other users may provide information about you as they use our Club Soda Services. For example, we may collect information about you from other users if they contact us about you.
You may be able to use your social media login (such as Facebook Login) to create and log into your Club Soda account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
We may receive info about you from our partners, for instance where Club Soda ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Information collected when you use our Club Soda Services
When you use our Club Soda Services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Club Soda Services. See below for more details:
We collect information about your activity on our Club Soda Services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
We collect information from and about the device(s) you use to access our Club Soda Services, including hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses
V. OTHER INFORMATION WITH YOUR CONSENT
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Club Soda Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the Club Soda Services).
VI. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
VII. HOW WE USE INFORMATION
We use your information to deliver and improve our Club Soda Services, to help keep you safe and to provide you with advertising that may be of interest to you. Our uses may include, but are not limited to:
Ensuring a consistent experience across your devices; conducting research and analysis of users’ behavior to improve our Club Soda Services and content; preventing, detecting and fighting fraud or other illegal or unauthorized activities; addressing ongoing or alleged violations of these terms and performing data analysis to better understand and design countermeasures against these activities; working to prevent fraudulent activities and legal compliance; enforcing our rights, for example our Terms.
To process your information as described in this policy, we rely on the following legal bases:
Providing our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our Club Soda Services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
VIII. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the Club Soda Services, and, in some cases, legal authorities.
Sharing information with other users
You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
Sharing information with our service providers and partners
We use third parties to help us operate and improve our Club Soda Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our Club Soda Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We evaluate our third party service providers prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
Sharing information for corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
Sharing information when required by law
We may disclose your information if reasonable or necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
Sharing information to enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as reasonable or necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
Sharing information with your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our Club Soda Services and on Club Soda Services or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
IX. YOUR RIGHTS
Below are the following tools for you to control your information:
Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service.
Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location Club Soda Services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Club Soda Services may lose full functionality.
Deletion. You can delete your account by using the corresponding functionality directly on the service.
Below are key points to know regarding your privacy rights:
Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms).
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us here.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
We cannot help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our Club Soda Services, for example access logs, as well as information from third parties, like when you access our Club Soda Services through a social media account. Additional information is provided below.
X. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
XI. RESIDENTS OF CALIFORNIA
Cal. Civ. Code § 1798.83
We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year.
California Consumer Privacy Act of 2018 (CCPA)
You have the right to know what categories and specific pieces of personal information are collected about you. You have the right to know what personal information is sold, shared, or disclosed with third parties. Subject to statutory exclusions, you have the right to request that we delete the personal information that we have collected about you.
You have the right to opt-out of the sale of your personal information. You may opt-out by visiting this link and following the directions.
If you exercise your rights under the California Consumer Privacy Act of 2018 (CCPA), you have the right to not be discriminated against.
To make a request related to the foregoing (limit one request per year), please send a request by email to the Privacy Administrator at [email protected] or by postal mail to Club Soda, Inc., Attn: Your California Privacy Rights, c/o Privacy Administrator, 9531 Santa Monica Blvd. # 122 Beverly Hills, CA 90210. All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
XII. HOW WE PROTECT YOUR INFORMATION
In order to protect both the personal information and the general information that we receive from you through our Club Soda Services, we have extensive security measures in place to protect the loss, misuse and alteration of the information stored in our database. These measures include the use of Secure Socket Layer (SSL) and/or strong encryption (3DES) technology during credit card transactions and administrative access to site data, as well as other proprietary security measures which are applied to all repositories and transfers of user information. We will exercise reasonable care in providing secure transmission of information between your computer and our servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure.
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here
In order to ensure that our systems and your information are protected against unauthorized access, theft and loss, we implemented a bug bounty program. For more information about our bug bounty program, please click here.
XIII. Data Security
The security of your Personal Information is important to us. We use generally accepted commercially reasonable safeguards, including “firewalls” and Secure Socket Layers, to protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Websites and provide us with your information at your own risk.
Confidentiality and Security
We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.
We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you.
Please keep in mind, however, that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While Club Soda strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using this site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this site and that any personal information, general information, or other data or information received from you through the site is provided to us at your own risk, which you expressly assume.
XIV. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our Club Soda Services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the Club Soda Services anymore.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
XV. CHILDREN’S PRIVACY
Club Soda intends only persons who are eighteen (18) years or older to use the Club Soda Services. Personal registration information submitted by a person under the age of 18 will not be accepted. Club Soda is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
In order to innovate and bring more meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
XVII. HOW TO CONTACT US
9531 Santa Monica Blvd. # 122
Beverly Hills, CA 90210