Privacy Policy
Last revised August 27, 2021
PLEASE READ THIS PRIVACY POLICY AND THE RELATED TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS WEBSITE.
This “Site” (as defined herein) is operated by Club Services, Inc. and its respective subsidiary, parent and affiliated companies (collectively, “Company”, “CSI” “us” or “we”). This privacy policy (“Privacy Policy”) applies to your use of our website located at www.clubwpt.com and any other online and mobile websites, blogs and interactive applications operated by Company that are related to www.clubwpt.com (collectively, the “Site”) (unless a different policy is provided on a particular site or application, in which case such different policy shall control) as well as your use of any software available on the Site (the “Software”). This Privacy Policy includes guidelines for protecting your information and, depending on your jurisdiction, describing your rights under applicable data protection laws. This Privacy Policy discloses what type of information is collected, the methods used to collect it, how Company utilizes the information to better serve all interested parties and the choices you have about the way your information is collected and used. Please read this Privacy Policy carefully. Your use of the Site indicates that you have read, and acknowledge the handling of your information as outlined in this Privacy Policy and any other applicable terms. The Terms and Conditions for this Site are incorporated herein by this reference. The information we collect is controlled by Club Services, Inc., which is headquartered in the United States at 17877 Von Karman Avenue, Ste. 300, Irvine, CA 92614.
If you are a California resident, please be sure to review the section “Additional Information for California Residents” below for important information, as required by California privacy laws, about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.
The Type of Information CSI Collects:
Although parts of our Site do not require you to be a subscriber and you can use them without submitting any “PII” (as defined below), some areas do require you to register and provide information that enables us to identify who you are. CSI generally collects PII with your specific knowledge and consent. For instance, when you enter a sweepstakes, complete a survey, make a purchase, subscribe to our newsletter or register for any portion of our services, you are asked to provide information (e.g., your e-mail address, name or phone number). Additional information such as your age is also requested, and will be used to verify your eligibility to win sweepstakes. Other information, such as gender, is requested. Providing us with PII about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Site’s features. For purposes of this Privacy Policy, personally identifiable information (“PII”) is personal information about an individual, such as a first and last name, phone number or email address or other individually identifiable information within the meaning of COPPA and the Federal Trade Commission’s Online Privacy Protection Rule found at 16 CFR 312.2.
For Younger Visitors and Their Parents:
ClubWPT.com is not directed toward children (individuals under thirteen years of age). We do not permit registration or use of ClubWPT.com by anyone under the age of 18, and we do not knowingly collect PII from children. In particular, if you are under 13 years of age (or under the age of 16 if you reside in the European Union), you should not provide any PII to any site on the Internet without the knowledge and permission of your parent or guardian. If Company discovers that a person under the age of 18 has provided Company with any PII, Company will use commercially reasonable efforts to delete such person’s PII from its system.
How CSI Uses the Information You Provide:
CSI uses this information to provide you with the service you have requested. If you subscribe to our newsletter, we will use your e-mail address to send you a confirmation notice and your e-mail address to send you your newsletter. Similarly, if you enter an online sweepstakes, we will use this information to notify you if you are a winner. We also use the information to communicate with you about new features, products or services, or to improve the services that we offer by tailoring them to your needs. From time to time, CSI may share e-mail addresses and sell or share all other information with our affiliates and with carefully selected companies who we think can offer you services and products of interest to you. If you no longer wish to have your information shared, write to us at privacy@theclubservices.com. If you do not wish to receive communications from us, you may opt out at any time, by following the unsubscribe instructions contained within the e-mail, or write to privacy@theclubservices.com. We also allow access to our database by third parties that provide us with services, such as technical maintenance or forums software, but only for the purpose of and to the extent necessary to provide those services. And if you choose to purchase items through features on our site, we may forward your information to third parties for services such as credit card processing and order fulfillment. There are also times when you provide information about yourself to us in areas of the Site that are managed or participated in by third parties, such as our featured partners. In such cases, the information will be used by us and by such third party(ies), each pursuant to its own policies. In certain circumstances, consistent with applicable law, we also provide your information to our advertisers, so that they can serve ads to you that meet your needs or match your interests. While CSI will seek to require such third parties to follow appropriate privacy policies, CSI does not bear any responsibility for any actions or policies of third parties. Please note that third parties may collect information about your online activities over time and across different websites when you use the Site. There may also be occasion when we are legally required to provide access to our database in order to cooperate with governmental agency investigations or other legal proceedings. In those instances, the information is provided only for that purpose.
In addition, we reserve the right to disclose, share and/or otherwise transfer user information, including without limitation PII and account information, in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of Company’s assets, or other fundamental corporate change, whatever form it may take. You will be notified via e-mail or prominent notice on our Site prior to a change of ownership or control of your PII, if your PII will be used contrary to this policy. For clarification and the removal of doubt, Company specifically reserves the right to transfer or share a copy of PII collected pursuant to this Privacy Policy from this Site or the Software, off-line or otherwise, to the buyer of that portion of its business relating to that information.
Third Party Sites Connections:
CSI may offer you the possibility to connect your accounts from third party sites, such as Facebook and Twitter (each, a “Third Party Site”), with the Site by an application programming interface (API) or other software. By allowing CSI to connect with your accounts on such Third Party Sites, you consent to CSI’s accessing the information in those accounts, which information may include PII. You likewise consent to CSI’s publishing on the Site any such information or actions you take on other such Third Party Sites. Any information accessed or published from your account on a Third Party Site on the Site is subject to CSI’s Terms and Conditions. It is your choice whether to use any such Third Party Site, and you understand that in some instances such Third Party Sites may request to access and publish information about you or your friends that is included in your CSI account.
Non-Personally Identifiable Information:
When your computer or mobile device contacts our web servers (for example, when you visit this Site or view an HTML e-mail), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate our Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses (see below for more information on IP addresses). We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail, advertising or promotional announcement or similar service. This information is used to analyze and improve this Site and to provide you with a more fulfilling and relevant experience. For example, we use personal data for analytical purposes when we track live events and which players came in what place. We also use personal data to track who is our Player of the Year based on how many titles that player has won, how many final tables they made, how many times they cashed in a tournament, and their total amount of earnings. We use aggregate data to track website usage, live event participation, demographic data to see where users are coming from.
Browser Cookies
Like many websites, we use browser “cookies”. Cookies are a website’s way of remembering who you are. A cookie is a small text file that is stored on your computer’s hard drive or stored temporarily in your computer’s memory. There are two kinds of cookies: those that are “session” oriented and those that are “persistent”. Session cookies delete from your computer when you close your browser. Persistent cookies retain information for later use tomorrow, next week, next month, or whenever they are set to expire. We use cookies to help us to identify account holders and to optimize their experience on our Site. Also, we will use cookies to monitor and maintain information about your use of this Site. Most web browsers accept cookies automatically. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, to delete cookies in the Google Chrome browser, go to the menu bar at the top left of the screen and select: Chrome › Clear Browsing Data. Then check 'Cookies and other site data' on the popup window that appears, and finally click the 'Clear Data' button. To choose how cookies are being set and saved, go to the top left of the Google Chrome menu bar and select: Chrome › Preferences › Privacy and Security › Cookies and other site data. Then simply check the corresponding boxes on that page to to define how you want cookies to be handled on the websites you visit. If you decline to accept cookies, you may not be able to take advantage of or participate in certain features of this Site.
Web Beacons
Our web pages or e-mail messages may contain a small graphic image called a web beacon, which is sometimes also called a "clear gif", that allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small or invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to our web pages or to monitor how our users navigate our Site, and we may include web beacons in e-mail messages in order to count how many of the messages we sent were actually opened or acted upon. We use web beacons to compile aggregate statistics about our Site and our marketing campaigns.
Use Of IP Addresses
An IP address is a number that is assigned to your computer or network when you are linked to the Internet. When you request pages from this Site, our servers log your IP address. We may use IP address for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Site. We may associate your IP address with the PII you provide.
We also may collect and store information about you that we receive from other sources to enable us to update and correct the information contained in our database and to provide product recommendations and special offers that we think will interest you.
Sensitive Information:
CSI uses all possible efforts to ensure the safety of your sensitive information. No website, internet transmission, computer system or wireless connection is completely secure. CSI cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site and the Software is at your own risk. CSI urges you to take steps to keep your information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account, and closing your web browser. In order to help us protect your sensitive information and PII further, you should be careful about providing your password to others.
Whenever you give CSI sensitive or confidential information, CSI will take commercially reasonable steps to protect the information by establishing a secure connection with your web browser. CSI uses the Security Socket Layer (“SSL”), an industry standard security protocol for encrypting sensitive information. Unfortunately, no security measures are perfect or impenetrable and data transmission over the Internet cannot be guaranteed 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to CSI and you do so at your own risk.
External Links:
Company may contain links to, or advertisements about, non-Company websites. Other sites may also reference, advertise, or link to Company Sites. Company does not endorse or sponsor other websites, is not responsible for the privacy practices or the content of non-Company sites, expressly disclaims any statements or assertions made on such websites, and denies all liability associated with your use of, and the content on, such other websites and advertisements. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through other websites. We encourage you to be aware of when you leave this Site and to read the privacy policies of each and every website that you visit.
Consent to Processing in the United States:
This Site is operated in the United States. By providing any information to Company, all users, including, without limitation, users in the member states of the European Union, Canada or elsewhere outside of the United States, fully understand and unambiguously consent to this Privacy Policy. By using our Site, participating in any of our services and/or providing us with your information, you consent and agree to the collection, transfer, storage and processing of your information to and in the United States.
International Transfers:
PII collected on the Site may be stored and processed in any country in which we or our affiliates, suppliers, or agents maintain facilities. By using the Site and/or the Software, you expressly consent to any transfer of information outside of your country. Where PII that we collect is transferred to and processed in the United States or anywhere else outside the European Economic Area (“EEA”) for the purposes described in this policy, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline.
This section does not address or apply to our handling of:
- information subject to an exemption from the CCPA
- publicly available information made lawfully available by state or federal governments
- personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of CSI
- personal information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described above in “The Type of Information CSI Collects” section above and for the purposes described in the “How CSI Uses the Information You Provide” section above. We do not sell this personal information.
| Categories of personal information Last Updated: August 27, 2021 |
Do we disclose for business purposes? | ||
|---|---|---|---|
| Name, Contact Info and other Identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | YES | YES | NO |
| Customer Records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, social security number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial or payment information. | YES | YES | NO |
| Protected Classifications: characteristics of protected classifications under California or federal law such as sex, age, and national origin. | YES | YES | NO |
| Purchase History and Tendencies: commercial information including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. | YES | YES | NO |
| Usage Data:internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any company websites, applications or other online services. | YES | YES | NO |
| Geolocation Data:precise geographic location information about a particular individual or device. | YES | YES | NO |
California Residents’ Rights. California law gives consumers the right to make the following requests, up to 2 times every 12 months:
- The right to request a copy of the personal information that we have collected about you in the prior 12 months.
- The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
- The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
You can submit a copy, deletion and right-to-know request by calling our toll-free phone number at (800) 987-9096 or by emailing us at privacy@theclubservices.com.
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. We do not discriminate against consumers when they exercise their CCPA rights.
Your California Privacy Rights under Shine the Light:
California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). As set forth in this Privacy Policy, we comply with this law by offering our visitors the ability to tell us not to share your personally identifiable information with third parties for their direct marketing purposes. To make such a request, consistently exercise your opt-out choice whenever you provide PII to us or send us a message at privacy@theclubservices.com. You must include this Site as the subject line, and your full name, e-mail address, and postal address in your message.
We may allow third-party companies to serve ads and/or collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie or third party web beacon to collect this information. Our Site does not recognize browser “Do Not Track” signals but several of our service providers who utilize these cookies or beacons on our web sites enable you to opt out of this behavioral advertising. To learn more about how to opt out of the behavioral advertising conducted by these providers you can visit https://www.networkadvertising.org.
NOTICE TO EEA RESIDENTS/YOUR PRIVACY RIGHTS:
The legal bases for using your PII
We collect, use, and share your PII where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- You have provided your consent to us using the PII (for example in relation to our electronic direct marketing activities);
- Our use of your PII is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); in these cases we will process your PII at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to processing as explained in the section below titled Your legal rights;
- Our use of your PII is necessary to perform a contract or take steps to enter into a contract with you (for example when you register and create an account or play in one of our live tournaments); and/or
- Our use of your PII is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to undertake vetting to comply with safety and security regulations or where we are required to disclose personal information to a court or tax authority).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your PII:
Right to access PII
You have a right to request that we provide you with a copy of your PII that we hold and you have the right to be informed of; (a) the source of your PII; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your PII may be transferred.
Right to rectify or erase PII
You have a right to request that we rectify inaccurate PII. We may seek to verify the accuracy of the PII before rectifying it.
You can also request that we erase your PII in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see Right to Object below); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase PII if the processing of your PII is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims
Right to restrict the processing of your PII
You can ask us to restrict your PII, but only where:
We can continue to use your PII following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your PII
You can ask us to provide your PII to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your PII
You can object to any processing of your PII which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your PII for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your PII to unaffiliated third parties for the purposes of direct marketing or any other purposes.
If you would like us to stop sending promotional communications to your email address, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication.
You may opt out of the use of your information for online interest-based advertising by following the steps detailed above in the section titled “How CSI uses the information you provide”.
Right to obtain a copy of personal PII safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your PII.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you would like to exercise any of the rights described above, please send us a request at privacy@theclubservices.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by emailing us at privacy@theclubservices.com. Subject to legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Revisions to Privacy Policy:
We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Privacy Policy, in whole or in part, at any time. When we amend this Privacy Policy, we will revise the “last updated” date located at the top of this Privacy Policy. For changes to this Privacy Policy that we consider to be material, we will place a notice on the Company website located at www.clubwpt.com by revising the link to read substantially as “Updated Privacy Policy” for a reasonable amount of time. If you provide information to us or access or use the Site in any way after this Privacy Policy has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Privacy Policy will be available on the Site and will supersede all previous versions of this Privacy Policy.
Choice of Law:
This Privacy Policy, including all revisions and amendments thereto, is governed by the internal laws of the State of California, without regard to its conflict or choice of law principles which would require application of the laws of another jurisdiction.
Contact Us:
If you have concerns or questions about any aspect of this Policy, you may e-mail our Privacy Policy Coordinator at privacy@theclubservices.com. We welcome your feedback. You can also send us regular mail at the following address:
Privacy Administrator
Club Services, Inc.
17877 Von Karman Avenue
Suite 300
Irvine, CA 92614