Effective Date: May 18, 2020
Table of Contents
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Your Choices
- Third Party Sites and Services
- Security Practices
- International Data Transfers
- How to Contact Us
- Information for California Residents
Personal Information We Collect
Information you provide to us.Personal information about you provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, date of birth, email and mailing addresses (including email address for any person assisting with your scheduling) and phone number.
- Profile data, such as your username and password that you may set to establish an online account with us, your interests and preferences, and any content uploaded to the Service (such as text, images, audio, and video, along with the metadata associated with the files you upload).
- Registration data, such as information that may be related to a service, application information for a Membership or an account or an event you register for, including, but not limited to, the following:
- Personal and professional goals, such as what you are passionate about, how you look to grow personally and professionally, how powerful you consider your professional network, how satisfied you are with your current career accomplishments and how you rank your personal well-being.
- Membership goals, such as why you joined The Happiness Club as a member, what you want to get most out of your Membership (i.e., strengthen network of senior power players, connect on deeper level with like-minded people, sharpen senior leadership skills, partake in interesting events and programming, access to space outside your office to meet people), what you want to make the biggest priority of your Membership, and what you would love to learn more about.
- Sponsorship information, such as whether you requested sponsorship from your company for your Membership.
- Communications, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Marketing data, such as information such your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
- Professional and employment data, including, but not limited to, the following:
- Company information, such as your company’s name, industry, type of company and size of company.
- Role information, such as your professional title, function, and any professional credentials (e.g., professional level and level you report into) and skills (e.g., whether you manage a P&L, sales or marketing budget or have raised or been involved in raising capital for a business)
- Other information of the type that may be included on a resume or curriculum vitae, such as whether you currently sit on a board at your company and/or outside of your company.
- Financial data, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history.
Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources such as:
- Other third parties, such as marketing partners and event co-sponsors.
Automatic data collection.We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites, app, and online services, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Precise geolocation data, such as when you authorize our mobile application to access your location.
Cookies and similar technologies. Like many online services, we use the following technologies:
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality and helping us understand user activity and patterns.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
- Software development kits, or SDKs, which are used to incorporate third party computer code into our App that allows our third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media or to add features or functionality to our App.
Nominations. Members may have the opportunity to nominate friends or colleagues to us. If you are an existing member, you may only submit a nomination if you have permission to provide the nominee’s contact information to us so that we may contact them.
How We Use Your Personal Information
Service delivery.We use your personal information to:
- provide, operate and improve the Service and our business;
- provide information about your Membership and our products and services;
- establish and maintain your user profile on the Service;
- communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or groups in which you participate, including introductions to other members and groups;
- understand your needs and interests, and personalize your experience with the Service and our communications;
- provide support and maintenance for the Service;
- to respond to your requests, questions and feedback.
Research and development.
We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.We make personal information into anonymous data by removing information that makes the data personally identifiable to you.We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing.We may collect and use your personal information for marketing purposes:
- Direct marketing. We may send you The Happiness Club-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Opt out of marketing” section below.
Compliance and protection.
We may use your personal information to:
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern our Service;
- protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
- comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
Other purposes with your consent.
In some cases we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.
How We Share Your Personal Information
- Service providers.
We may share your personal information with partners. For example, if we co-host an event with a third party, we may share your information to the extent related to such event.
- Payment processors.
- Other users and the public.
Other parties may be able to view your content when you provide such content to your public user profile or voluntarily disclose it in a manner that other users or the public can view. In addition, your username will be displayed to other users through the Service, and other users may be able to contact you through the Service. Content that you post publicly on, through or in connection with the Service, including on third party services such as a social media platform, may also be public. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
- Compliance and protection.We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
In this section, we describe the rights and choices available to all users.
Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at firstname.lastname@example.org.You may continue to receive service-related and other non-marketing emails.
Do Not Track.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.We currently do not respond to “Do Not Track” or similar signals.
To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Third Party Sites and Services
The Service may contain links to other websites and other online services operated by third parties.These links are not an endorsement of, or representation that we are affiliated with, any third party.In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions.Other websites and services follow different rules regarding the collection, use and sharing of your personal information.We encourage you to read the privacy policies of the other websites and online services you use.
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
International Data Transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not directed at, and The Happiness Club does not knowingly acquire or receive personal information from, children under the age of 13. If we learn that any user of the Service is under the age of 13, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.
How to Contact Us
Please direct any questions or comments about this Policy or privacy practices to email@example.com. You may also write to us via postal mail at:
Project 1972, Inc.
117 Hudson Street, 2nd Floor
New York, NY 10013
Information for California Residents
This section applies only to California residents.It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access.You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- You can ask us to delete the Personal Information that we have collected from you.
- You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights by emailing us at firstname.lastname@example.org. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.
- As part of this process, government identification may be required.Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
- We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- We do not sell your personal information.
Personal information that we collect, use and share
We are required to explain the categories of Personal Information we collect by reference to the categories specified by the CCPA (in bold), as defined here, which are described in the list below. For each category, we list the type of data we collect and the source of that data as described in the section above entitled “Personal Information We Collect.” We have not sold your personal information in the preceding 12 months.
- What we collect: Contact data, profile data, registration data, communications
- Sources:You, business partners, nominations
- Commercial Information
- What we collect: Contact data, profile data, registration data, online activity data
- Sources: You, business partners, automatic collection
- Financial Information
- What we collect: Financial data
- Sources: You
- Geolocation Data
- What we collect: Device data, precise geolocation data
- Sources: Automatic collection
- Online Identifiers
- What we collect: Contact data, profile data, online activity data, device data
- Sources: You, automatic collection
- Internet or Network Information
- What we collect: Device data, online activity data
- Sources:Automatic collection
- Inferencesdrawn from any of the above information to create a profile reflecting your preferences, characteristics, and behavior.
- May be derived from:Profile data, registration data, device data, online activity data
- Professional or Employment Information
- What we collect: Contact data, profile data, registration data, professional and employment data
- Sources: You
- Protected Classification Characteristics,
- What we collect: Registration data, may also be revealed in other data we collect
- Sources: You
The business/commercial purposes for which we use each category of Personal Information above are described in the section above entitled “How We Use Your Personal Information.” The categories of third parties to which we disclose each category of Personal Information above of Personal Information for business purposes are described in the section above entitled “How We Share Your Personal Information.”