THE CAMARGO CLUB

PRIVACY POLICY

Last updated September 21, 2023

This Privacy Policy for The Camargo Club ("Camargo Club," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our website (the “Site”)  or our Mobile Application (the “Mobile App” and collectively with the Site, the “Online Services”) (as defined in our Terms of Use) or when you engage with us in person, by telephone, by mail, or otherwise. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with.
If you do not agree with our policies and practices, please do not use our Online Services.  By visiting or using our Online Services, you are agreeing to the terms of this Privacy Policy and its accompanying Terms of Use. If you still have any questions or concerns after reading through this Privacy Policy and our Terms of Use, please feel free to contact us at the contact details provided at the end of this Privacy Policy.
We reserve the right to change this Privacy Policy at any time in our sole discretion. Each time you access or use our Online Services, such access or use shall be subject to the Privacy Policy posted on our Site at the time of such access or use.  Any changes to this Privacy Policy will be posted on the Site.  You agree that no other notification of changes to this Privacy Policy is required and that all changes will apply to your access or use of the Online Services on and after such changes are posted.  If you do not agree to the changed terms, then you must immediately stop using the Online Services and request that we close any on-line account you may have created with us.

1. What Information Do We Collect?

In the course of operating the Online Services, we will collect and/or receive the following types of information, which you authorize us to collect and/or receive.
Personal information You Give to Us.  We collect personal information that you voluntarily provide to us when you register for an account on our Online Services, express an interest in obtaining information about us or our services, when you participate in activities on the Online Services, or otherwise when you contact us.  You may choose whether to provide certain information, but you may not be able to utilize all aspects of the Online Services if you choose not to provide certain information.
Types of Personal Information We Collect. The personal information that we collect depends on how you interact with the Site, the choices you make, and the features you use. The personal information we collect may include some or all of the following:

• Name
• Date of birth
• Gender
• Email address
• Telephone number
• Postal address
• Account name
• Credit and debit card number
• Marital status
• Military or veteran status
• Photograph
• Username
• Password

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Payment Information. If you choose to make monthly service payments or other purchases through our Online Services, you will be required to provide your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, or similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by third-party vendors pursuant to the terms and conditions of their respective privacy policies and terms of use.
Information Automatically Collected.  We may automatically collect certain information when you visit, use, or navigate the Online Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Online Services, and other technical information. This information is primarily needed to maintain the security and operation of our Online Services, and for our internal analytics and reporting purposes.
The information we or our service providers automatically collect may include:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers or service providers may automatically collect when you access or use our Online Services and which may be recorded in log files. Depending on how you interact with us, the log data may include your IP address, device information, browser type, and settings and information about your activity on the Online Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity), error reports (sometimes called "crash dumps"), and hardware settings.
Device Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Online Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We may collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Online Services.
Cookies.  We may use cookies, pixels, and other technologies (collectively, "cookies") to recognize your browser or device, learn more about your interests, and provide you with certain features of our Online Services and for additional purposes, including:

• Recognizing you when you sign-in to use our Online Services (if sign-in is required).
• Keeping track of your specified preferences.
• Conducting research and diagnostics to improve our content, products, and services.
• Preventing fraudulent activity.
• Improving Security.
• Delivering content relevant to your interests on our Online Services.
• Measuring and analyzing the performance of our Online Services.

Third parties such as search engines, providers of measurement and analytics services, and social media networks may also use cookies. Third parties use cookies in the process of delivering content relevant to your interests, to measure the effectiveness of our Online Services, and to perform services on behalf of us.
You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to block cookies, and when cookies will expire. If you block all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

2. For What Purposes Do We Use Your Personal Information?

We process your personal information for a variety of reasons, depending on how you interact with our Online Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to an account on our Online Services, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user, provide support or respond to inquiries. We may use your information to provide you with the requested service or information, provide you with support in using our Online Services or to respond to your inquiries.
To send information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
To protect from harm or to comply with legal requirements. We may process your information when necessary to prevent harm to any person or entity or to comply with any applicable legal requirements.

3. Do We Share Your Information?

Information about our clients is an important part of our business, and we are not in the business of selling our client’s personal information to others.  However, we may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).  We may obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this Privacy Policy.
Third Party Service Providers.  We may employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing search results and links (including paid listings and links), processing payments, transmitting content, and creating, modifying, or hosting our Online Services. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.
Affiliates and Business Partners. We may share your information with our affiliates or business partners in connection with providing services to you, responding to your inquiries or providing you with marketing materials or information.
To protect from harm or to comply with legal requirements. As noted above, we may share your information when necessary to prevent harm to any person or entity or to comply with any applicable legal requirements.
Information shared with third parties will be subject to the privacy policies of such third parties.

4. How Can I Access and Modify My Information and Communication Preferences?

If you have provided us with any personal information, you may access, remove, review, and/or make changes to the same by contacting us at the contact details provided at the end of this Privacy Policy. However, you should be aware that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to using our Online Services (e.g., requests for support). We may also deliver notifications to your mobile device. You can disable these notifications by deleting the relevant service or by changing the setting on your mobile device.

5.  How Secure Is My Information?

We have implemented commercially reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we use reasonable commercial efforts to protect your personal information, transmission of personal information to and from our Online Services is at your own risk. You should only access the Online Services within a secure environment.

6. Are Minors Allowed to Use the On-line Services?

Our Online Services are intended for use by individuals that are at least 18 years or older. If you are less than 18 years old, you must have permission from a parent or guardian prior to using our Online Services. However, children under the age of 13 are strictly prohibited from using our Online Services. By using the Online Services, you represent that you are at least 13 years or older.
We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. If we learn that personal information from users less than 13 years of age has been collected, we will, as applicable, deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 13, please contact us at the contact details set forth at the end of this Privacy Policy.

7.  Opting Out of Marketing and Promotional Communications.

We do not anticipate making routine marketing and promotional communications, but to the extent you have subscribed to any marketing or promotional messages, you can unsubscribe from our marketing and promotional communications at any time by contacting us using the contact details provided at the end of this Privacy Policy, or by clicking on the “unsubscribe” link located on the bottom of any marketing and non-transactional e-mails. You will then be removed from our marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

8.  Account Information.

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact details at the end of this Privacy Policy.  Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

9.  Privacy Rights for California Residents. 

The California Consumer Privacy Act, as amended from time to time (CCPA), gives California residents additional rights regarding the collection, use, disclosure, and sale of personal information. Under the CCPA, “personal information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This does not include information that is publicly available, deidentified, or aggregated. For the purposes of this section, we will refer to this information collectively as “Personal Information.”

Your Right to Know

If you are a California resident, you may ask us to:

• Disclose what Personal Information we have about you.
• Tell you what we do with your Personal Information.
• Delete your Personal Information.
• Direct us not to sell or share your Personal Information.
• Correct inaccurate information.
• Limit our use and disclosure of your sensitive Personal Information.

 
The CCPA defines “selling” as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration. We do not sell your information, but we do share your information as outlined in Section 3, “Do We Share Your Information?” and below in the subsection titled What Personal Information Do We Disclose?
What Personal Information Do We Collect?
The table below represents the categories of Personal Information we have collected, the sources from which the Personal Information was collected, the purpose for the collection, and the categories of third parties with whom we share Personal Information. The information is accurate as of the 12 months preceding the Effective Date of this Privacy Policy.
The table includes the use of the term “business purposes.” Under the CCPA, “business purposes” include the following:

• Auditing relating to ad impressions and compliance.
• Ensuring security and integrity.
• Debugging to identify and repair errors that impair functionality.
• Providing nonpersonalized advertising without third party disclosure or profile building that may alter a consumer’s experience outside of current interaction with the business.
• Maintaining and servicing accounts, providing customer service, processing and fulfilling orders/transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
• Providing advertising and marketing services within limited circumstances.
• Undertaking internal research for technological development and demonstration.
• Maintaining the quality or safety of services or devices owned or controlled by the business and to improve, upgrade, or enhance such services or devices.

Categories of Personal Information Collected	Sources From Which Personal Information was Collected	Purpose for the Collection	Categories of Third Parties with whom we Share Personal Information
Name	User	Business Purposes	Business Partners Data analytics providers
Date of birth	User	Business Purposes	Business Partners Data analytics providers
Gender	User	Business Purposes	Business Partners Data analytics providers
Email Address	User	Business Purposes	Business Partners Data analytics providers
Telephone Number	User	Business Purposes	Business Partners Data analytics providers
Postal Address	User	Business Purposes	Business Partners Data analytics providers
Account name	User	Business Purposes	Business Partners Data analytics providers
Credit and debit card number	User	Business Purposes	Business Partners Data analytics providers
Marital status	User	Business Purposes	Business Partners Data analytics providers
Military or veteran status	User	Business Purposes	Business Partners Data analytics providers
Photograph	User	Business Purposes	Business Partners Data analytics providers
Records of products or services purchased, obtained, or considered	User	Business Purposes	Business Partners Data analytics providers
Account number, username, and password	User	Business Purposes	Business Partners Data analytics providers
Geolocation data	User	Business Purposes	Business Partners Data analytics providers
Cookies, beacons, pixel tags, or similar technology	User	Business Purposes	Business Partners Data analytics providers
Browsing history	User	Business Purposes	Business Partners Data analytics providers
Search history and user’s interaction with the website and mobile app	User	Business Purposes	Business Partners Data analytics providers

 
The CCPA also allows California residents the option to request how a business uses information for commercial purposes. The CCPA defines “commercial purposes” as advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction. As of the 12 months preceding the Effective Date of this Privacy policy, we have not used your data for any commercial purposes as defined by the CCPA.
What Personal Information Do We Disclose?
We have not sold Personal Information to third parties in the 12 months preceding the Effective Date of this Privacy Policy. The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

• Name
• Date of birth
• Gender
• Email address
• Telephone number
• Postal address
• Account name
• Credit and debit card number
• Marital status
• Military or veteran status
• Photograph
• Records of products or services purchase, obtained, or considered
• Account number, username, and password
• Geolocation data
• Cookies, beacons, pixel tags, or similar technology
• Browsing history
• Search history and user’s interaction with the website and mobile app

How Do I Submit a Request to Know?
You can submit your request to us by contacting us at the contact details provided at the end of this Privacy Policy. You may make this request up to twice a year, free of charge.
 
How Do We Process a Request to Know?
We will process your request after verifying your identity. The verification process will require us to use commercially reasonable methods to verify your identity, including but not limited to, asking you to verify two data points that you previously provided to us in connection with your membership with us. Any Personal Information used to verify your identify will be used only for verification purposes.
When Will We Respond to Your Request?
We will respond to your request within 45 calendar days. If we run into issues processing or complying with your request, we will notify you of those complications and may extend our response time by another 45 days.

Your Right to Delete

The CCPA gives California residents the right to request that we delete your Personal Information that we have collected or maintain. However, we are not required to delete Personal Information that is necessary to complete business activities such as completing transactions, performing security measures, or for otherwise lawful activities.
How Do I Submit a Request to Delete?
You can submit your request to us by contacting us at the contact details provided at the end of this Privacy Policy.
 
How Do We Process a Request to Delete?
We will process your request after verifying your identity. The verification process will require us to use commercially reasonable methods to verify your identity, including but not limited to, asking you to verify two data points that you previously provided to us in connection with your membership with us. Any Personal Information used to verify your identify will be used only for verification purposes. 
When Will We Respond to Your Request?
We will respond to your request within 45 calendar days. If we run into issues processing or complying with your request, we will notify you of those complications and may extend our response time by another 45 days.

Your Right to Opt-Out of Sale of Sharing

The CCPA gives California residents the right to request that a business stop selling or sharing their Personal Information. Note that “sharing” in this context refers to sharing for cross-context behavior advertising purposes. We have not sold Personal Information to third parties in the 12 months preceding the Effective Date of this Privacy Policy and we do not share Personal Information for cross-context behavioral advertising. However, you may still submit a request to opt-out of sales by using one of the methods listed at the end of this Privacy Policy. This will ensure that your request is in our records if our Privacy Policy changes in the future.

Your Right to Correct

The CCPA gives California residents the right to request that a business correct inaccurate information that they have about you.
How Do I Submit a Request to Correct?
You can submit your request to us by contacting us at the contact details provided at the end of this Privacy Policy.
 
How Do We Process a Request to Correct?
We will process your request after verifying your identity. The verification process will require us to use commercially reasonable methods to verify your identity, including but not limited to, asking you to verify two data points that you previously provided to us in connection with your membership with us. Any Personal Information used to verify your identify will be used only for verification purposes. 
When Will We Respond to Your Request?
We will respond to your request within 45 calendar days. If we run into issues processing or complying with your request, we will notify you of those complications and may extend our response time by another 45 days.

Your Right to Limit

The CCPA gives California residents the right to request that business use your sensitive personal information, such as your social security number, financial account information, precise geolocation data, or generic data, only for limited purposes, such as providing you with services that you request.
How Do I Submit a Request to Limit?
You can submit your request to us by contacting us at the contact details provided at the end of this Privacy Policy.
 
How Do We Process a Request to Limit?
We will process your request after verifying your identity. The verification process will require us to use commercially reasonable methods to verify your identity, including but not limited to, asking you to verify two data points that you previously provided to us in connection with your membership with us. Any Personal Information used to verify your identify will be used only for verification purposes. 

Right to Non-Discrimination for the Exercise of Rights Under the CCPA.We will not discriminate against any California resident for exercising any rights under the CCPA.

Shine the Light Request
California Civil Code Section 1798.83, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing or via email to us using the contact details provided at the end of this Privacy Policy.