Privacy Policy

Clubly LLC, a New York limited liability company ("Company," "we," "us," or "our") provides this Privacy Policy because we know that you, like us, care about how your information is collected, used, shared, retained and secured. This Privacy Policy applies to information collected when you visit our website https://clubly.vip(our "Website"), use our mobile applications for attendees and organizers (our "Apps"), or access or use services ("Services") that we make available from time to time through our Website or Apps, including event discovery, ticket purchases, free RSVPs, table reservations, order confirmations, QR code ticketing, check-in tools, organizer dashboards, and related marketplace functionality (collectively, the Website, Apps and Services hereinafter our "Platform"). Clubly operates solely as a facilitating marketplace and ticketing technology provider. Clubly is not the event host or promoter, and the applicable event organizer is the merchant of record for ticket sales and related event transactions.

By using our Platform, you agree to the terms of this Privacy Policy and the accompanying Terms and Conditions, and you acknowledge our collection, use, disclosure, and retention of information as described in this Privacy Policy. If you do not agree, discontinue use of the Platform. Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms and Conditions. Where required, we may also obtain your separate consent or affirmative choices for specific practices, such as optional marketing communications, cookie preferences, or organizer specific SMS marketing.

If you are a California resident, please see the "Additional Disclosures for California Residents" section below. If you access the Platform from outside the United States, please also review the sections below addressing international access and data transfers. Clubly is based in the United States, stores data on U.S. servers, and does not currently offer localized services or represent compliance with non-U.S. privacy regimes except as expressly stated in this Privacy Policy. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the "Contact Us" section.

Personal Data: Personal Data means data about an identified or identifiable individual, including information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. For purposes of this Privacy Policy, Personal Data may include, by way of example, your name, email address, phone number, date of birth, profile information, transaction information, ticketing or reservation information, organizer-related account information, device identifiers, and other information described in this Privacy Policy.

Usage Data: Usage Data is data collected automatically through your access to and use of the Platform and related infrastructure, including, by way of example, browser type, device type, operating system, IP address, session activity, page views, clicks, feature usage, referral sources, crash data, performance data, and information regarding how you interact with our Website, Apps, emails, tickets, reservations, and other Platform features.

Cookies: Cookies are small pieces of data stored on your device (computer or mobile device). We and our service providers may use cookies and similar technologies, such as pixels, SDKs, local storage, and analytics tools, to remember preferences, keep you signed in, understand usage patterns, measure performance, support security, and help operate and improve the Platform.

Data Controller: Data Controller means the natural or legal person who determines the purposes for which and the manner in which any personal data is processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data to the extent we determine the purposes and means of processing such data under applicable law.

Data Processors (or Service Providers): Data Processor means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively, including providers that support payment processing, ticket delivery, SMS messaging, email communications, analytics, mapping, customer support, fraud prevention, storage, security, and other Platform operations.

Data Subject (or User): Data Subject is any living individual who is using our Platform and is the subject of Personal Data. For example, a Data Subject may include an attendee, account holder, event purchaser, free RSVP user, table reservation user, organizer representative, venue representative, guest list contact, or other individual whose information we collect in connection with the Platform.

Event Organizers / Venues: We may work with event organizers, venues, promoters, hosts, operators, and related event partners that use the Platform to create listings, sell tickets, manage reservations, communicate with attendees, process entry, administer refunds, and operate their events. If you purchase a ticket, make a reservation, RSVP to an event, join a guest list, or otherwise engage with an event through the Platform, certain of your Personal Data may be shared with the applicable organizer or venue as described in this Privacy Policy.

We collect information about you when you use the Platform, for example, when you create an account, browse events, purchase tickets, RSVP to free events, make table reservations, receive tickets or confirmations, interact with organizers, use our consumer or organizer apps, communicate with customer support, join marketing communications, attend events, or otherwise access or use the Platform. We also collect information in connection with organizer onboarding, event creation and management, guest list administration, refunds, ticket scanning, and related marketplace operations. This information may include Personal Data and Usage Data.

Here is a listing of the information that we collect, how we collect the information, and how we use and share that information, including the categories of information we collect: The exact categories of information we collect depend on how you interact with the Platform, whether you are an attendee or organizer, whether you complete a paid or free transaction, what device and settings you use, and which features, communications, and third party integrations are involved.

While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Date of birth
• Billing address, city, state, ZIP or postal code, and country, if collected in connection with a transaction or organizer account
• Payment and transaction information, including payment method details processed through Stripe, the last four digits of a payment card, card brand, purchase amounts, fees, refund data, payout data, and related transaction records
• Organizer and venue information, including organizer name, venue name, business name, event-related business information, payout-related information, connected Stripe account information, and organizer onboarding information
• Account information, including login credentials, profile image, username or handle, and account preferences
• Event and reservation information, including ticket selections, free RSVPs, table reservations, guest list status, QR code or booking reference, order history, check-in and attendance records, and refund status
• Communications information, including customer support messages, Intercom communications, email delivery data, SMS delivery data, and marketing preference records
• Organizer-imported guest information, including attendee or guest names, email addresses, and phone numbers uploaded or entered by organizers through the Platform
• Social media or profile information, such as Instagram handle, if you choose to provide it
• Device, browser, and technical information, including IP address, device identifiers, operating system, browser type, user agent, approximate geolocation derived from IP, and related usage information
• Analytics and behavioral information, including activity on the Platform, session interactions, feature usage, and event browsing and purchase behavior
• Any other information you choose to provide to us through the Platform or in communications with us

We may offer parts of our Platform through websites, apps, platforms, and services operated or controlled by separate entities. When you interact with other entities, including when you leave our Platform, those entities may independently collect information about you and solicit information from you. The information collected and stored by third parties is subject to their policies and practices, including what information they share with us, your rights and choices on their services and devices, and where they store information. We encourage you to review their terms of use and privacy policies. Our Platform may also integrate with third party technologies and service providers that support payment processing, organizer onboarding, SMS messaging, email delivery, mapping, analytics, error monitoring, customer support, digital wallet ticketing, file or image storage, and related functionality. Your interactions with those third party services may be subject to the applicable third party's own terms, policies, and practices.

The Company uses the collected data for various purposes, including the following:

• To provide and operate the Platform
• To process purchases, RSVPs, reservations, payments, and refunds
• To manage attendee and organizer accounts
• To send tickets, confirmations, receipts, and service updates
• To support organizer tools and attendee communications
• To improve features, performance, and user experience
• To analyze usage and monitor Platform activity
• To prevent fraud, abuse, and technical issues
• To enforce our terms and protect our rights
• To comply with legal obligations and disclosed purposes

We may also use your Personal Data to contact you with newsletters, marketing or promotional materials and our own and third-parties' goods and services that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. We may also send you marketing or promotional communications, including email or SMS communications, where permitted by law and consistent with your preferences and consent choices. Marketing SMS communications from organizers are managed on a per-organizer opt-in basis. You may opt out of marketing emails by using the unsubscribe link in the message, and you may opt out of marketing SMS by adjusting your settings, where available, or replying STOP to the applicable text message.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Company will retain your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Platform, maintain accounts, complete transactions, operate events, provide support, enforce our agreements, and protect our business and users. We may retain certain information while your account remains active, and we may retain certain records for longer periods where needed for legal, operational, tax, accounting, fraud prevention, dispute resolution, chargeback handling, security, or compliance purposes. For example, account profile data may be retained while an account is active, while certain short-term technical records such as unverified accounts, session data, verification codes, refresh tokens, and audit logs may be retained for shorter periods based on business and security needs. Certain transaction and business records, such as orders, tickets, payments, disputes, events, SMS subscription records, and support tickets, may be retained for longer periods, including indefinitely unless deletion is required or appropriate. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Platform, or we are legally obligated to retain this data for longer time periods. We may also retain technical, analytics, and security-related data as reasonably necessary to monitor performance, investigate abuse, detect fraud, maintain system integrity, debug issues, and improve the Platform.

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We and our service providers may process and store information in the United States and other jurisdictions where we or they operate.

If you are located outside the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the United States and other jurisdictions. Data protection laws in the US and other jurisdictions may be different from those of your country of residence. Clubly is based in the United States, and our Platform is primarily intended for U.S.-based operations and users. We do not represent that the Platform complies with non-U.S. privacy laws except as expressly stated in this Privacy Policy.

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We use commercially reasonable administrative, technical, and organizational safeguards designed to protect Personal Data against unauthorized access, loss, misuse, alteration, and disclosure. These measures may include encryption in transit, secure infrastructure, access controls, authentication tools, monitoring systems, and third-party service providers that support payment security, fraud prevention, communications security, and Platform operations.

Our Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. However, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

If a security incident affecting Personal Data occurs, we may notify affected users by email, SMS message, in-Platform notification, or other reasonable means as required by applicable law and the circumstances of the incident.

Payment information is processed by third-party payment processors, including Stripe, and is not stored by us in full payment card form. We may also use third-party service providers to support security, fraud prevention, bot detection, error monitoring, communications delivery, and infrastructure protection. Those providers process information in accordance with their own systems and contractual obligations to us, and you should review their privacy policies where appropriate.

We share information, which may include personal information, we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we may have disclosed and may have shared information with in the last 12 months, include the following:

Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities. We may also share information with business, marketing, promotional, venue, event, and technology partners in connection with operating the Platform, supporting events, facilitating communications, or offering related services or campaigns.

Event Organizers and Venues. If you purchase a ticket, make a reservation, RSVP to an event, join a guest list, or otherwise engage with an event through the Platform, we may share your Personal Data with the applicable organizer, venue, promoter, host, or related event partner. This may include your name, email address, phone number, ticket or reservation details, guest list status, purchase history for that event, check-in status, and related participation information. Organizers and venues may use this information for event administration, entry management, customer communications, guest list management, refund handling, and related event operations. Organizers may also export attendee information for their events, including contact details and attendance records, using reporting tools available within the Platform.

Business Transfers. We share information in the event of, or during negotiations of, any proposed or actual merger, reorganization, dissolution or similar corporate event, the sale of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Disclosure to Public Authorities. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We also share information to protect the rights, property, life, health, security and safety of us, the Services or anyone else.

Disclosure for Law Enforcement. Under certain circumstances, Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may also disclose information to investigate suspected fraud, chargebacks, abuse, unauthorized activity, violations of our terms or policies, or threats involving the Platform, event organizers, attendees, or third parties.

We may employ third-party companies and individuals to facilitate our Platform ("Platform Service Provider"), to provide the Platform on our behalf, to perform Platform-related services or to assist us in analyzing how our Platform is used. These third parties may have access to some of your Personal Data to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose. These providers may support, among other things, payment processing, organizer onboarding, SMS delivery, email delivery, analytics, customer support, mapping, digital ticketing, storage, fraud prevention, bot protection, performance monitoring, and infrastructure services.

We use bot-detection and abuse-prevention providers such as Cloudflare Turnstile to help distinguish legitimate users from automated activity. These services may process device signals, browser information, IP address data, and interaction behavior in order to protect the Platform from fraud, spam, credential abuse, and unauthorized access. Cloudflare's processing of this information in connection with Turnstile, including when it operates in an invisible or non-interactive mode, is described in the Cloudflare Turnstile Privacy Addendum, available at https://www.cloudflare.com/en-gb/turnstile-privacy-policy/, which is incorporated into this Privacy Policy by reference.

Our Platform may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Our Service is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Service. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Service or through any of its features, register on the Service, use any of the interactive or public comment features of this Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without authorization, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Certain events offered through the Platform may be subject to additional age restrictions, including 18+ or 21+ requirements established by the applicable organizer, venue, or law. We may collect date of birth or related information in connection with registration and account administration, but physical age verification at the venue or event is the responsibility of the applicable organizer or venue unless expressly stated otherwise.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If required by law or if we make material changes, we may also provide additional notice through the Platform, by email, or by other reasonable means.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. In addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

If you have any questions about this Privacy Policy, your information, or your rights and choices under this Privacy Policy, please contact us at:

Where available through the Platform, users may also access certain privacy and account controls directly, including account settings, marketing preferences, data export tools, and account deletion tools. Submission of a request through the Platform does not limit our ability to take reasonable steps to verify the request and the identity of the requester.