Largest Club on Clubhouse

Come Together LLC dba Startup.club (the “company”), is a club on Clubhouse, website, and podcast. The following privacy policy applies when you use the website located at www.startup.club (the “Site”). The Site provides the Service as explained in our Terms of Use. We respect and protect the privacy of our Site users. This Data Protection and Privacy Policy (“Policy”) explains how we collect and use your information and is part of our Terms of Use when you use our Site. Your Consent By using our Site, you consent to our Data Protection and Privacy Policy. If you don’t agree, please don’t use our Site.

Definitions         

Company         
“Company” means, with a place of business at 701 North Andrews, Fort Lauderdale, FL 333111, USA.         

GDPR         
“GDPR” means that General Data Protection Regulation Act. (This is a law that applies in the European Economic Area (EEA).)         

Data Controller         
“Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. The Company is the Data Controller for the personal data you submit via the Site.         

Data Processor         
“Data Processor” means any natural or legal person who processes the data on behalf of the Data Controller.         

Data Subject         
“Data Subject” is any living individual who is using our Site.

Principles for Processing Personal Data
Our principles for processing personal data under the GDPR are:

• Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.
• Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.
• Transparency. The Data Subject must be informed of how his/her data is being collected, processed and used.
• Accuracy
• Storage Limitation
• Confidentiality and Integrity

What information do we collect?
When you sign up to the Site, you’ll be asked to provide certain information about yourself, such as your name and email. If you sign up via a social network like Facebook, Instagram and Linkedin, your agreement (and our access to your information) takes place when you instruct, accept, or allow Facebook, Instagram and Linkedin to register you for the Site or otherwise connect you to the Site. We will collect such information as you allow based on your social media settings and the policies of the social media site. We may also collect information to verify your social media credentials. We and our third-party service providers may collect certain information about your use of our Site. For example, we may collect and/or use:

• Log information (including your IP address, browser type, Internet service provider, referring and exit pages, operating system, dates/time of access, and related data)
• Information collected by cookies and tracking pixels (as discussed below)
• Web beacons (also called “Internet tags” or “clear gifs”; used to count visitors to our Site and which pages were viewed and links clicked)
• Embedded scripts (code temporarily downloaded onto your device to collect information about your interactions with the Service and thereafter deleted or deactivated)

Information Sent by Your Mobile Device
We collect certain information that your mobile device sends when you use our Site, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services. Location Information When you use our Site, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device. Where do we store your information? Your information may be stored in our own servers or in servers owned by third-party cloud storage providers. Third-party storage providers may not use your information except as provided in this Privacy Policy. How do we use your information? Information we collect from you might be used:

• To verify your identity when you return to the Site
• To provide you with Services
• To notify you about changes to our Site and Services
• To gather analysis or other information to improve our Site and Services
• For marketing purposes
• To personalize ads you see when you visit the Site
• To respond to your messages and comments
• To provide customer support
• To detect, prevent, and address technical issues
• To send you technical notices

Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and using the personal data described in this Policy depends on the personal data we collect and the specific context in which we collect the information:

• We need to perform a contract with you.
• You have given us permission to do so.
• Processing your personal data is in our legitimate interests.
• We need to comply with the law.

Please be aware that if you do not provide personal data, we may be unable to provide some Services to you.

Our role as a host of third-party content
We provide a platform for you and others to access podcasts and blog posts, whose content is, as per our Terms of Use, sole liability of the uploading Guest. We cannot ensure, a priori, that the Guest’s content will not breach data protection regulations or infringe others similar rights. We also cannot prevent a Guest to make lawful references or uses of your personal data. To the extent we become aware of any infringing or unlawful activity regarding your personal data, we will act in accordance to our Terms of Use and take down any content that is in breach of such terms. If any of our Guest has published on our website your personal information without your consent, breached your privacy or somehow infringed your rights, you should (i) let us know by email to hello@startup.club and (ii) contact the uploader directly and ask them to remove the content. We can intermediate such contact, upon your request. If you cannot reach an agreement with the owner of the content, you can request us to have the content removed by stating the grounds on which the use of such information is infringing upon your rights.

Do we use cookies or tracking pixels?
Yes. Cookies are small files that include an anonymous unique identifier. Cookies let us recognize your browser and remember certain information about you in order to personalize your experience of our Site. We also use cookies to compile aggregate data about traffic to our Site so that we can improve our Site and Site. We may use both persistent and session cookies. Persistent cookies remain on your computer after you close your session and until you delete them; session cookies expire when you close your browser. A tracking pixel is a tiny pixel-sized image that allows us to track your Site visits, advertising impressions, and other types of Internet activity. It’s also sometimes called a web bug, beacon, or page tag.

Do We Use Google AdWords or other remarketing methods?
Yes. We may use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our Site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our Site. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page. Do we use Google Analytics? Yes. Users who visit the Site and have JavaScript enabled are tracked through Google Analytics.  Google Analytics collects information anonymously and reports website trends to us without identifying individual visitors.  Google Analytics collects a variety of information from users, including  the Internet protocol (IP address) that is used to connect your computer to the Internet (which it does not report to us), your Internet service provider (ISP), browser type, type of operating system, the full Uniform Resource Locator (URL) clickstream to, through, and from our Site, including date and time, cookie, the length of time you spend on particular pages, which links you click while on our Site, and similar Site visit information.  Google Analytics data is shared with Google. For more information on Google Analytics or to opt-out of having your information shared through Google Analytics, visit: https://www.google.com/intl/en/analytics/privacyoverview.html. For more information on Google’s privacy policy, visit https://www.google.com/intl/en/policies/privacy/. We use this information to make our Site easier to find on the Internet and to improve our Site by learning which pages and features are interesting to our visitors. We treat this information as non-personal information and do not attempt to connect it to personally identifiable information, except as otherwise required by law.

Do we transfer your data to other countries?
We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States, Canada or other destinations outside the European Economic Area (“EEA”). Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA.

• If you are located in the EEA, we will only transfer your personal data if:

the country to which the personal data will be transferred has been granted a European Commission adequacy decision;

• the recipient of the personal data is located in the US and has certified to the US-EU Privacy Shield Framework;
• we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules.

How do we respond to “Do Not Track” signals?
We may track your browsing behavior to better tailor suggestions and information for you. Some third-party sites also keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. You can opt out of certain tracking by adjusting the settings on your browser. However, many websites (including the Site) may not respond to such signals. There are also browser extensions that may block tracking. Again, they may not be effective in all cases.

How long do we store your information?
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We intend to store some of your information User Content indefinitely.

What about links to other websites?
We may provide links to or compatibility with other websites.  However, we’re not responsible for the privacy practices employed by those websites or the information or content they contain.

How do we protect your information?
We use Site-appropriate physical, electronic, and other procedures to safeguard and secure the information we collect. However, please be aware that the Internet is an inherently unsafe environment, and that hackers are constantly working to defeat security measures. Thus, we cannot guarantee that your information will not be accessed, disclosed, altered or destroyed, and you accept this risk.

How can you protect your information?
We urge you to take steps to keep your personal information safe by not sharing it with others or posting it online.

Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information (PII) for commercial or marketing purposes. We may share your PII with third-party processors, which can include:

• Payment processors
• Providers of email management and distribution tools
• Providers of security and fraud prevention services
• Providers of date aggregation and analytics software

We will, if required by a valid court order, provide your personal information in a civil or criminal proceeding. We will not share any PII that we have collected from or regarding you except as described below. Information Disclosed in Connection with Business Transactions. If we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, may be disclosed or transferred to a third party acquirer in connection with the transaction. Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity. Not Intended for Children Our Site is not intended for children under the age of 13. We do not knowingly or specifically collect information from or about children under the age of 13. Notice for Minors If you are under the age of 18, and If our Site publicly displays your content, at any time you can delete or remove your content using the deletion or removal method within our Site. If you have questions about how to remove your content, or you need assistance, you can contact us at hello@startup.club. Although we offer deletion capability, you should be aware that your removal of your content may not ensure complete or comprehensive remove the content or information posted through the Site, especially if it has been shared by others. Also, there may be circumstances in which the law does not require or allow removal even if requested. Data Protection Rights If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us at hello@startup.club. In certain circumstances, you have the following data protection rights:

• The right to be informed of your rights
• The right to access, update or to delete the information we have on you
• The right of rectification (to correct mistakes)
• The right to erasure (known as “the right to be forgotten”)
• The right to restrict processing of your data
• The right to data portability
• The right to withdraw consent

Withdrawing Consent
If you wish to withdraw your consent to process your personal data, please contact us at hello@startup.club. If you withdraw your consent, this will not make processing which we undertook before you withdrew your consent unlawful. Changes to our Privacy Policy If we decide to change our Privacy Policy, we will post those changes on this page. We may also, but are not required to, send you an email notice. Contact Us If you have questions about our Privacy Policy, please contact us at hello@startup.club.