Privacy Policy

Information you provide

• Account data: name, email, phone, username, password, date of birth, and jurisdiction.
• Identity verification (KYC) data: government ID, photo/selfie, address, and, where required, Social Security Number or tax identifier.
• Payment data: payment method details processed by our payment partners (we do not store full card numbers).
• Promotion data: entries, alternative-method-of-entry submissions, and prize-claim and tax documentation.
• Communications: messages to support and survey or marketing responses.

Information collected automatically

• Device and usage data: IP address, device identifiers, browser, app interactions, and approximate location.
• Cookies and similar technologies (see our Cookie Policy).
• On-chain data: wallet addresses and transactions associated with your account.

Information from third parties

• Identity, fraud-prevention, sanctions/AML screening, and analytics providers; payment processors; and referral sources.

• To provide, operate, and secure the Services and your wallet.
• To administer promotions, verify eligibility, conduct drawings, and award and report prizes.
• To verify identity and comply with KYC, AML, sanctions, tax, and other legal obligations.
• To process payments, recurring deposits, and digital-asset transactions.
• To detect and prevent fraud, abuse, and multiple or automated accounts.
• To personalize features and product routing, and to provide customer support.
• To send service and marketing communications (you can opt out of marketing). Where required, we rely on consent or legitimate interests as the legal basis.

• Service providers and processors (cloud hosting, KYC/AML, payments, custody, analytics, communications) under contract.
• Regulators, law enforcement, and others where required by law or to protect rights and safety.
• Blockchain networks, which are public by design, when you transact.
• In a merger, financing, acquisition, or sale of assets, subject to this Policy.
• We do not sell personal information for money.

We retain personal information for as long as needed to provide the Services and to meet legal, tax, accounting, and AML record-keeping obligations (which may require retention for 5 years or more after account closure), then delete or de-identify it.

We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is fully secure, and we cannot guarantee absolute security.

U.S. state privacy rights (including California / CPRA)

• Depending on your state, you may have rights to know, access, correct, delete, and limit certain uses of your personal information, and to opt out of sale/sharing and targeted advertising.
• Submit requests via hello@theclubcoin.com. We will verify your identity and will not discriminate against you for exercising your rights.

Marketing

• You can opt out of marketing emails via the unsubscribe link and manage notification settings in your account.

The Services are not directed to anyone under 18 (or 19 where applicable). We do not knowingly collect personal information from minors. If you believe a minor has provided information, contact us and we will delete it.

Our service is not currently available to users outside the United States.

We may update this Policy. We will post the updated version with a new effective date and, where required, provide additional notice.