Your Privacy Is Crucial to us
– Privacy policy update 15th June 2020 –
We want our privacy policy (the “Privacy Policy) to be crystal clear and simple to understand, we therefore want to inform you about the use of your personal data.
It is essential to underline that ClubDeal.com is an independent and private platform dedicated to a sensitive population of HNWI members. As such, the protection of your privacy is paramount to our existence. We therefore make every effort to secure your data on world-class datacenters (ISO 14001, ISO 50001, ISO 27001) located in Switzerland for an optimum guarantees of security and confidentiality.
Data protection is a key concern for ClubDeal.com which has been placing this matter as a priority from inception.
We know that the careful use of your personal data is very important to you, and we appreciate your trust. Data protection is very important to us, and ClubDeal.com fully complies with the legal requirements of the European Union’s General Data Protection Regulation (GDPR) while collecting, processing, and using your data. In the course of serving our clients, ClubDeal.com may obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately. This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Club Deal” or “ClubDeal” refers to ClubDeal, Inc. and its affiliates.
Responsible processing
We protect and treat your personal information as if it were our own.
Independence
We are fully independent and only care about the protection of our private community
What personal data we collect and why we collect it
Information Collection, Use, and Sharing
We are a fully independent private platform, and we are the sole owners of the information collected on this Website, as such we will not sell or rent this information to anyone, and we do not share your data with third parties for advertising purposes. We only have access to/collect information that you voluntarily give us via email or other direct contact from you.
We will use your information to respond to you, regarding the reason you contacted us. We will contact you in the future to tell you about Services updates, such as notices of investment opportunities and new projects, or to send you useful information that we believe will be of interest, or changes to the Terms and Conditions and/or the Privacy Policy. We will not share your information with any third party outside of our organization, other than as necessary to process your request, e.g. to complete an investment. In compliance with the European Union’s General Data Protection Regulation (GDPR), data subjects have the right to access their data and to have incorrect data corrected.
Consent
When you provide us with personal and commercial information with respect to a contemplated transaction, you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no. If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us with the contact form. By providing us with information and documents presenting a Project, you expressly consent to their disclosure on the Website where they will be freely accessible by all Registered Users.
Disclosure
When you invest in a project, the Issuer will know your account name, and the amount you have committed. Issuers never receive Investors’ credit card details or other payment information, which are exclusively processed by payment gateways. If a Project you have invested in is successfully funded, the Issuer will receive the email address associated with your account, and may contact you on a regular basis to provide you with updates concerning the Project. We are also authorized to disclose your data if we are required by law to do so, e.g. transmission to law enforcement agencies and supervisory authorities for the purpose of averting dangers to national security, public safety or for crime prosecution.
The Information We Have about You
If you deal with ClubDeal in your individual capacity (e.g. as a private client), or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):
- Your full name, phone number, email address, organization, birth-date, IP addresses, and other contact details;
- Extensive information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.
Security
To protect your personal information both online and offline, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment. If you choose a third-party payment gateway to complete your investment, then a third party payment gateway processes your banking data, which is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Third party services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the Services they provide to us. However, certain third-party service providers are located in a different jurisdiction than either you or us, and have their own privacy policies. We recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. To the extent necessary for the processing of the transactions entered into through the Website, you agree that personal information may be communicated to third parties outside France.
Disclosure
We use “cookies” on this site. A cookie is a piece of data stored on your computer that do not contain private information. Cookies help us improve your access to our Website, identify visitors, and enables Users to use certain functions. The content of cookies may vary and so we use: functional and analytics cookies.
- Functional cookies: let us store your preferences and automatically connect you to our website. They improve your experience and facilitate using our services.
- Analytic cookies: we collect information on the use of our site to see what information you find useful or superfluous.
What rights you have over your data
If you have an account on this site you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Changes to the Privacy Policy
We may revise this Privacy Policy from time to time to comply with law or to meet our changing business requirements. If we do this, we will post the changed Privacy Policy on the Website and will indicate at the top of this page the date the Privacy Policy were last revised. By continuing to use the Website and Services after we have made any such changes, you understand and agree to be bound by the terms of any such updates and amendments. If our Company is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to provide our Services to you.