Last Updated: June 10, 2021
Transparency/Notice – Types of Personal Information We Collect and How We Use It
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Country Club Surf Club and the requirements of applicable law. Some of the ways that Country Club Surf Club may collect Personal Information include:
You may provide Personal Information directly to Country Club Surf Club. through interacting with the Services, making online or in-store purchases, participating in surveys, during events such as sweepstakes, and requesting Services or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Types of Personal Information We Collect
Country Club Surf Club collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees. (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Country Club Surf Club, making an online or in-store purchase, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Creating an Account with Us. When you make a purchase online or in an Country Club Surf Club store, we will automatically create an Account for you. To create an Account, we’ll collect certain information that can be used to identify you, such as your name, postal address and phone number, as well as other optional information you may provide like the type of clothing you prefer. If you create an Account using your login credentials from one of your third-party services accounts such as Facebook or Google (each an “Third-Party Account”), we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the Third-Party Account permit us to access. If you create an Account through the Site or one of your Social Networking Services (“SNS”) Accounts, we may also collect your gender or date of birth.
Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, create an account, register for Country Club Surf Club’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
Posting on the Site. You may post reviews of your purchases on Country Club Surf Club’s Site. You should be aware that, when you disclose information about yourself in on Country Club Surf Club’s Site, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Registration for Sweepstakes or Contests. Occasionally, Country Club Surf Club may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
Automatic Data Collection. Our servers automatically record certain information about how Individuals use our Services (we refer to this information as “Event Data”). Event Data may include information such as an Individual’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Event Data to administer the Services and we analyze (and may engage third parties to analyze) Event Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to Individuals’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Information Submitted Via Services. You agree that Country Club Surf Club is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Country Club Surf Club will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Country Club Surf Club and to enhance our ability to provide you with information about our business, products, and Services.
How Country Club Surf Club. Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. Country Club Surf Club may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Generally manage Individual information and Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Country Club Surf Club’s Services;
Contact you to answer requests for customer support or technical support;
Allow you to register for events.
Administrative Purposes. Country Club Surf Club may use Personal Information about you for its administrative purposes, including to:
Measure interest in Country Club Surf Club’s products and Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual Accounts and activities on Country Club Surf Club’s Services and systems, and, in Country Club Surf Clubs discretion, changes to any Country Club Surf Club policy;
Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Country Club Surf Club Products and Services. Country Club Surf Club may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Country Club Surf Club may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our Services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by mail. From time to time, Country Club Surf Club may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Country Club Surf Club’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Anonymous and Aggregated Information Use. Country Club Surf Club may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Country Club Surf Club’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Country Club Surf Club may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Country Club Surf Club and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Country Club Surf Club’s Services may offer various tools and functionalities. For example, Country Club Surf Club allows you to provide information about your friends through our referral services, such as “Invite a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Country Club Surf Club or any other Third Parties for any other purpose.
Other Uses. Country Club Surf Club may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
Third-party websites, Social Media platforms, and Software Development Kits
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Country Club Surf Club does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Country Club Surf Club’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We use Third-Party software development kits (“SDKs”), such as the adjust Inc. SDK, as part of the functionality of our Services. Third-Party SDKs may allow Third Parties including advertisers to collect your personal information to provide content that is more relevant to you.
Third-Party Payment Processing
When you make purchases through the Services, we process your payments through a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of Country Club Surf Club, including your name, email address, address and other billing information.
Human Resources Data
Country Club Surf Club collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
Workflow management, including assigning, managing and administering projects;
Human Resources administration and communication;
Payroll and the provision of benefits;
Compensation, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
Job grading activities;
Performance and employee development management;
Organizational development and succession planning;
Benefits and personnel administration;
Helpdesk and IT support services;
Internal and/or external or governmental compliance investigations;
Internal or external audits;
Litigation evaluation, prosecution, and defense;
Diversity and inclusion initiatives;
Restructuring and relocation;
Emergency contacts and services;
Compliance with statutory requirements;
Processing of Employee expenses and travel charges; and
Acquisitions, divestitures, and integrations.
Onward Transfer—Country Club Surf Club May Disclose Your Information
Information We Share
Information Shared with Our Services Providers. We may engage third-party services providers to work with us to administer and provide the Services. Some of examples of these third-party’s services are payment processing, shipping, and handling returns. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose. When you make a payment, the third-party payment processor (e.g., Braintree, Stripe, or Cayan) receives your full payment information and we receive only a funding confirmation.
Country Club Surf Club has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. Country Club Surf Club may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Country Club Surf Club may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Country Club Surf Club. Country Club Surf Club requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Country Club Surf Club provided them.
Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, Country Club Surf Club may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Country Club Surf Club related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Country Club Surf Club policies or contracts; (v) to collect amounts owed to Country Club Surf Club.; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
All Personal Information collected via or by Country Club Surf Club may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Country Club Surf Club, you consent to the storage of your Personal Information in these locations.
Opt-Out (RIGHT TO RESTRICT PROCESSING)
We offer you choices regarding the collection, use and sharing of your Personal Information, and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Country Club Surf Club’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting firstname.lastname@example.org. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
Country Club Surf Club may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Country Club Surf Club may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Human Resources Data
With regard to Personal Information that Country Club Surf Club receives in connection with the employment relationship, Country Club Surf Club will use such Personal Information only for employment-related purposes as more fully described above. If Country Club Surf Club intends to use this Personal Information for any other purpose, Country Club Surf Club will notify the Individual and provide an opportunity to opt-out of such uses.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
Rights of Access, Rectification, Erasure, and Restriction
Although Country Club Surf Club makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Country Club Surf Club is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Country Club Surf Club determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Country Club Surf Club will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
The Services are not directed to children under 16 years of age, and Country Club Surf Club does not knowingly collect Personally Identifiable Information from children under 16 years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child’s Account.
Redress/Compliance and Accountability
Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Country Club Surf Club will endeavor to comply with the law or contract.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Country Club Surf Club does not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Country Club Surf Club or to which Country Club Surf Club discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Country Club Surf Club or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Country Club Surf Club or Country Club Surf Club’s Agents.