PRIVACY POLICY

Updated August 18, 2023

INTRODUCTION

The Lox Club, Inc., and its affiliates (“Lox Club,” “Company,” “we,” “us,” “our”) are committed to maintaining a safe and trustworthy private community and we understand that privacy and confidentiality are of the utmost importance to our members, applicants, attendees, and other users (collectively, “you,” “your,” or “Users”).

To that end, the policy set forth below (the “Privacy Policy”) describes our information practices when you use our applications (“App(s)”), any websites operated by The Lox Club, Inc. that link to this Privacy Policy (“Sites”), and certain features thereof, or related services, including those related to RSVPing and/or attending events which are advertised, featured, hosted or otherwise disseminated through the Apps or Sites (collectively, “Service(s)”).

Please click the following links to learn more about our Privacy Policy:

1. WHAT INFORMATION WE COLLECT

Information You Provide in Connection with Membership. To apply for membership to the App, you must provide us with certain information to verify your identity and evaluate your real-world connection to our existing members. Some of the information that you provide may be considered “special” or “sensitive” in certain jurisdictions. By choosing to provide this information, you consent to our processing of it. Any information you provide may be viewable by other users of the Service. If you communicate with other users within the Service, you provide us with the content of your conversation. Should you contact us with an inquiry, we may collect the content of that correspondence or interaction. You may change your personal information (other than your date of birth and Instagram handle) at any time within the App settings.

Specifically, we collect the following categories and types of personal information:

Identifiers, such real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, physical characteristics or description, address, telephone number, education, or employment.
Characteristics of protected classifications under federal law – such as race, religion, gender, or age – or under California law – such additional categories as sexual orientation.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation data.
Visual information, such as photographs.
Professional or employment-related information.
Education information.
Hometown information.
Height.
Religion.
Information regarding your interests and disinterests.
Inferences drawn from the above categories.

We collect the following categories of sensitive information:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.
Racial or ethnic origin, or religious or philosophical beliefs.
Contents of App messages unless we are the intended recipient of the communication.
Information collected and analyzed concerning your sexual orientation.

Information We Automatically Collect. In addition to the information you provide, certain information will be automatically collected as you use the Service, including, but not limited to, the operation system used by your device, your device type and ID, your IP address, how and how often you interact with other users and your access times. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.

Information Other Users Provide. In addition to the information that you choose to provide to us, other users may provide information about you as they use the Service if, for instance, they contact us about you, or you are a contact in their phone.

Information We Get from Third Parties. We may collect personal information and non-personal information about you from third parties.

Surveys. From time to time, we send you surveys from us or brand recognition surveys on behalf of advertisers. If you participate in these surveys, we will have access to your survey responses.

No Financial Information. As we exclusively accept payment through third party services such as Apple and Stripe, we will never ask for your credit card information and your financial details are, and will remain, secured by and subject to the applicable third party’s security and privacy policies.

2. HOW WE USE INFORMATION WE COLLECT

We may use or disclose the personal information we collect for one or more of the following purposes:

To provide you with our Service, which includes:

Creating, maintaining, customizing, and securing your account with us.
Providing customer support and responding to your inquiries, including investigating, and addressing your concerns, and monitoring and improving our responses.
Processing your requests, purchases, transactions, and payments.
Verifying customer information.
Providing advertising or marketing services to you.

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and help maintain the safety, security, and integrity of our App, Site, products and services, databases and other technology assets, and business.
To personalize your App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our App, third-party sites, and via email or text message (with your consent, where required by law).
For testing, research, analysis, and product development, including developing and improving our App, Site, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To fulfill our financial obligations.
To provide you with employment opportunities.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. HOW WE SHARE INFORMATION

Except as otherwise described in this Privacy Policy, we do not share personal information with companies, organizations, and individuals outside of the Company unless one of the following circumstances applies:

Information Shared with Other Users. When you register as a user of a Service and create your profile, your App profile will be viewable by other users of the Service. Such other users will be able to view information you have provided to us directly or through Instagram, such as:

your Instagram username,
photos you upload,
your name,
your age,
city of residence,
hometown,
your biography, and
information you have in common with the person viewing your profile, such as mutually followed Instagram accounts.

In addition, a mutual “like” by you and another user enables you to chat with that person through the Service. Should you engage in a conversation through a Service via text chat, status post or video chat, that user with whom you are communicating will see the content of that interaction. However, the Instagram information automatically available to users of the App will not exceed the information otherwise accessible through your Instagram profile. Therefore, a “private” Instagram user profile will still be private; only the content you choose to share with users will be visible.

Affiliate Dating Services. We own and operate The Lox Club, Inc. family of dating platforms. With your consent, we will share your information with users of other The Lox Club, Inc. dating platforms, and vice versa, to help you expand your dating opportunities. Please access your account settings to provide or remove this consent.

Member-Hosted Events. Certain members of our platform may, upon approval from us, organize member-hosted events. If you attend one of these member-hosted events, we may share limited information about you with the user who hosted the event. This limited information may include your name, email address, age, gender preference, Instagram, and employment.

Non-Member Information Shared with Other Users. If you are not a member of the App, but RSVP to an event using our events service, whether upon receiving a text message invitation or otherwise, your name and phone number may be made available to other users of the Service.

Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you the Service. The service providers we use help us to:

Run, operate, and maintain our Services through third-party platforms and software tools;
Perform content moderation and crash analytics;
Run email and mobile messaging campaigns;
Perform marketing analytics;
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Administer live events and promotions, including registering attendees, managing check-in and attendance, verifying eligibility and prize fulfilment;
Provide payment attribution; and
Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Third Party Marketing and Advertising Organizations. With respect to website cookies, we share your information with third-party marketing and advertising partners to market our services on our Sites and other websites that you may visit. To learn more, please see our Cookie Policy.

For legal reasons. We will share personal information with companies, organizations, or individuals outside of the Company if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

meet any applicable law, regulation, legal process or enforceable governmental request;
enforce or apply our terms and conditions and other agreements;
detect, prevent, or otherwise address fraud, security, or technical issues; or
protect against harm to the rights, reputation, property or safety of the Company, our clients, our consumers, or the public as required or permitted by law.

Non-personal information. We may share non-personal information (in aggregated and/or non-aggregated form) publicly and/or with our partners, like publishers, advertisers or connected sites. For example, we may share information about campaign performance with advertisers.

4. COOKIES AND “DO NOT TRACK”

To make our Sites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, contents of your shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy.

You may wish to restrict the use of cookies. Please be aware that some features of our Sites may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We may send cookies to your browser to support behavioral targeted advertising. Through it, we may collect data about websites visited, content viewed, searches on other websites, ad interaction, interaction with advertiser websites and other click and browsing behavior.

You can opt out of our in-app mobile online behavioral advertising by changing the settings on your mobile device. On Apple devices, the setting may be under Settings-Privacy-Advertising-Limit Ad Tracking. On Android devices, the setting may be under Settings-Account & Sync-Google-Ads-Opt Out of Interest-Based Ads.

Advertisers and third-party ad networks may also participate in our ad network and may also utilize cookies to deliver advertisements and monitor the performance of such advertisements. Many third-party ad networks have agreed to provide an "opt out" mechanism for their ad cookies. The collection of information through cookies by such third parties will be governed by their own privacy policies and practices, over which we have no control.

You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

“Do Not Track.” Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. We may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

5. AGE POLICY

Must be of Age. We restrict our Services to people who are 18 years of age and older. Only applicants 18 and over will be considered for acceptance, and we are not liable should an applicant misrepresent their age in their application. Should we become aware of a user who is not at least 18 years of age, we will immediately remove that user from our Service. We do not knowingly collect, maintain, or use information from children under the age of 18. If you become aware that a child under 18 has provided us with personal information, please contact us at hey@loxclubapp.com. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.

6. INFORMATION SECURITY AND RETENTION

Information Security. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Please be advised that, although we take reasonable technological precautions to protect your data, no website, application, or data transmission can be guaranteed to be 100% secure. Therefore, we cannot and do not guarantee that your information will be secure. Any transmission of data at or through our website, Services or Apps is at your own risk.

Retention. We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, possible re-enrollment with our Service, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

7. CHANGE OF CONTROL

If we enter discussions to sell, merge, or otherwise reorganize our business, we reserve the right to transfer and disclose all data (including personal and non-personal user information) to prospective and/or actual purchasers or investors. We will require that such purchasers/investors treat the transferred data as described in the Privacy Policy that exists prior to the change unless and until you consent to a new Privacy Policy.

8. PRIVACY POLICY CHANGES

We reserve the right to change our Privacy Policy at any time without notice. However, these changes will not reduce your privacy on a retrospective basis. We will post any Privacy Policy changes on this page, and it is your responsibility to check this page for updates.

9. CONTACT INFORMATION

If you have questions or complaints relating to this Privacy Policy, please contact us at hey@loxclubapp.com.

10. PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR EEA & UK INDIVIDUALS

Lawful Bases for Processing. If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal information is as follows:

The performance of your contract or to enter into the contract and to take action on your request. For example, processing your membership application and completing your account registration.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improving our services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal information to record your requests to exercise your rights and to verify your identity for such requests.
The consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described in the “How We Share Your Information” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided above.

EEA and UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:

Access, correct, update, or request deletion of your information.
Object to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
Withdraw your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

To exercise any of these rights, contact us using the contact details provided above, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

International Transfers of Data. Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such a data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail the transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information in this Privacy Policy.

11. PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

Third Party Marketing. If you are a California resident, California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of a Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hey@loxclubapp.com.

Access to Specific Information and Data Portability Rights. Residents of California have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights,” below), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting, selling, sharing, or disclosing that personal information, and the categories of personal information disclosed for such purpose(s).
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.

Request for Deletion. California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights,” below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Do Not Sell or Share My Personal Information. Residents of California have the right to opt out of the sale or sharing of their personal information. We do not sell your personal information. However, we may use your personal information to provide personalized or targeted advertising. In such circumstances, you have the right to direct us not to share your personal information for such purposes. If you wish to actualize this right, please visit this webpage: Do Not Sell or Share My Personal Information.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods or services to you, or as otherwise minimally permitted.

Right to Equal Service and Price. California residents have the right to receive equal service and price from us, even if you exercise a privacy right.

Exercising Your Rights. To exercise any rights described above, please email us at hey@loxclubapp.com. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the email address above and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking action and, depending on the circumstances, any rights that you may have to appeal our decision.

Response Timing and Format. We will confirm receipt of your request within ten (10) business days. Then, we will endeavor to respond to the request within forty-five (45) days of its receipt. If we require more time (up to 90 days), such as to verify your identity, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.