Club Del Internet, LLC Privacy Policy

This Privacy Policy explains how Club Del Internet, LLC LLC ("Club Del Internet, LLC", "we" or "us") collects, uses, and discloses information about you when you access or use our websites, mobile application and other online products and services, shop in our stores, contact our customer service team, engage with us on social media, apply for a job with us, or otherwise interact with us (collectively, the "Services").

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, fill out a form, participate in a survey, review, contest or promotion, make a purchase, apply for a job or upload your resume, communicate with us via third party social media sites, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, credit card and other payment information, age, location, your information (name, breed, date of birth, gender, etc.) and any other information you choose to provide.

Other Information We Collect

When you access or use our Services or transact business with us, we automatically collect information about you, including:

• Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
• Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, site interaction data, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Visual Information: We utilize cameras in our stores for security purposes and to measure and observe customer traffic patterns to improve our stores and services.
• Location Information: We may derive the approximate location of your device from your IP address. In accordance with your device permissions, we may also collect information about the precise location of your device. You have the ability to stop the collection of precise location information at any time (see Your Choicesbelow for details).
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons and other tracking mechanisms. Cookies are small data files stored on your hard drive or in your device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and help us understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices

Information Collected from Other Sources

We may also obtain information about you from other sources. For example, we may collect information about you from third parties, such as mailing list providers, data enhancement sources and publicly available sources, including information you submit in a public forum (e.g., a blog, chat room, or social media). If you apply for a job with us, we will receive your application information from our job applicant processing partners. Additionally, if you create or log into your account through a social media site, we may have access to certain information from that site, such as your name, account information, and friends lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

We use the information we collect to deliver the products and services you request and customize your experience with us. We also use the information we collect to:

• Provide, maintain and improve our products and services;
• Conduct audits related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Club Del Internet, LLC and others;
• Debug to identify and repair errors that impair existing intended functionality;
• For limited, internal and operational use, such as to enable our website to function;
• Perform services on behalf of us or a service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, or conducting analytic services;
• Undertake internal research for technological development and demonstration;
• Undertake activities to verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, us;
• Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, and events offered by Club Del Internet, LLC and others, and provide news and information we think will be of interest to you (see Your Choicesbelow for information about how to opt out of these communications at any time);
• Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, and browsing and purchasing behavior;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Evaluate your application and qualifications for employment with us; and
• Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We may share information as follows:

• With vendors, service providers, and consultants that perform services for us, including e-mail and mobile marketing, analytics, web hosting, call center services, payment processing, coupon delivery, and data enhancement;
• With entities who may provide financing for your purchase;
• With the public, if you post information online and elect to make it available to the public, such as by writing a product review on our website;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Club Del Internet, LLC or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Club Del Internet, LLC and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

Social Sharing Features and Third-Party Privacy Policies

The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take on our Services with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. Your interactions with those features are governed by the privacy policies of the entities that provide these features. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit their privacy policies.

Please note that when you apply for a job with us, the privacy policies of our job applicant processing partners may govern the submission of your application information.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Club Del Internet, LLC and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.clubdelinternet.com/choices. Your device may also include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Interest-Based Ads" or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Data Retention and Security

Data Retention

We store the information we collect about you and your pet(s) for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Security

We maintain administrative, technical and physical safeguards to protect your personal information. However, no e-commerce solution or website is completely secure. You are also responsible for taking reasonable steps to protect your personal information, such as using strong passwords and using different passwords across your online accounts. We will never request your password or credit card information through email.

Children's Personal Information

We recognize the particular importance of protecting privacy where children are involved. We do not knowingly collect personal information online from children under the age of 16.

Transfer of Information to the U.S. and Other Countries

Club Del Internet, LLC is based in the United States and we process and store information in the U.S. and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Your Choices

Account Information

You may update and correct certain account information you provide to us at any time by logging into your account or calling our Customer Care number at 1-888-839-9638 (U.S. Customers) or 1-321-309-9065 (Customers outside of the U.S.).

Location Information

When you first launch any of our mobile applications that collect precise location information, you will be asked to consent to the application’s collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our mobile applications, or certain features thereof, may no longer function properly. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile applications from your device. Certain mobile devices contain geo-location tracking capability. We may use such capability or other geo-location tracking technology to identify the location of devices in our store or nearby for marketing, to generate coupons or other offers, and for analytical purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. The Help or similar function of your browser should contain instructions to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional emails from Club Del Internet, LLC by following the instructions in those emails or by logging into your account and changing your preferences. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

SMS Privacy Policy

By participating in any of our mobile programs, you agree to receive automated marketing phone calls and text messages at the phone number your provided at opt-in. Your consent to receive marketing messages is not required to make a purchase. You agree to notify Club Del Internet, LLC at the Contact Us information below in the event that you change or disconnect your mobile phone number. Phone calls made and text messages sent to your mobile device may be generated using automated telephone dialing technology. Message and data rates may apply and are billed by and payable to your mobile service provider. Delivery of messages are subject to the effective transmission by your mobile service provider and any policies or terms established by your mobile service provider. To cancel general promotional messages from Club Del Internet, LLC, text "STOP" to ________and to cancel transactional messages from Club Del Internet, LLC, text “STOP” to ______________.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your California Privacy Rights

Consumers residing in California have certain additional rights with respect to their personal information under the California Consumer Privacy Act or ("CCPA") (California Civil Code  1798.100 et seq.) and the "Shine the Light" Law (California Civil Code  1798.83).

California Consumer Privacy Act

Additional Disclosures Related to the Collection, Use, Disclosure and Sale of Personal Information

Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, characteristics of protected classifications under California or U.S. law, geolocation data, Internet or other electronic activity information, and inferences drawn about any of the preceding categories of information. We also collect the following categories of personal information from job applicants: professional or employment related information and education information. For examples of the data points we collect, please see "Collection of Information" .

Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in "Use of Information" .

Categories of Sources of Personal Information: We collect personal information directly from you when you interact with our Services, shop in our stores, contact us through customer service or other mechanisms, or use our pet-focused services, automatically when you access or use our Services, purchase products or services from us and from third-party sources as described in "Information Collected from Other Sources" .

Categories of Third Parties with Whom We Share Information: We may share your personal information with third parties as described in the "Sharing of Information"  .

Categories of Personal Information Disclosed: In the preceding 12 months, depending on your interactions with us, we may have disclosed the following categories of personal information for business or commercial purposes: identifiers, financial information, characteristics of protected classifications under California or U.S. law, geolocation data, Internet or other electronic activity information, and inferences drawn about any of the preceding categories of information.

Sale of Personal Information: California law requires that we provide transparency about personal information we "sell," which for the purposes of the CCPA, means scenarios in which Club Del Internet, LLC has shared personal information with partners in exchange for valuable consideration. In the preceding 12 months, depending on your interactions with us, we may have "sold" the following categories of personal information: identifiers and internet or other electronic network activity information. Club Del Internet, LLC is a pet specialty retailer in the business of offering pet related goods and services to pet parents. As such, Club Del Internet, LLC’s business model does not include sharing your identifying information such as your name, email address, phone number, or postal address to third parties in exchange for money. However, we do share identifiers such as name, email or postal address with our subsidiaries to offer you our pet-related goods and other identifiers such as cookies and the advertising identifier associated with your mobile device with our advertising partners to show our ads that are targeted to your interests.

Your Consumer Rights

What are the CCPA Consumer Rights?

• California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. They may also request the categories of personal information we have collected about them, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell their personal information, and the categories of personal information we have disclosed and sold about them in the preceding 12 months.
• California consumers have the right to request deletion of their personal information (subject to certain exceptions).
• Opt Out of Sale.California consumers have the right to opt out of the sale of their personal information. California consumers the age of 16 have the right to opt out of these sales at any time. We do not knowingly collect online or sell personal information about consumers under the age of 16.
• California consumers have the right to receive equal service and price and not be discriminated against for exercising any of their CCPA rights, however, financial incentive programs may condition participation on collection of personal information.

How to request CCPA Consumer Rights: California consumers may make a rights request by calling 1-888-839-9638 or visiting the following pages:

• Access
• Deletion
• Do Not Sell My Personal Information

To confirm your identity and ensure we respect your privacy and security, we will prompt you to verify your request by logging into your account (if applicable), replying to an email, or calling us. Please follow the instructions provided when you submit your rights request. Caution, if you choose to have your personal information deleted, we can no longer provide you with certain Services, such as Treats membership (and you will be deleting any Treats points balance you have accrued), auto ship enrollment, or remember your preferences for certain pet services such as Grooming, because we will no longer know who you are. Notwithstanding a deletion request, we may retain personal information that is necessary for us to fulfill our legal obligations or that is not otherwise subject to deletion under applicable law.

Financial Incentives Program: You have the right to receive equal service and price and not be discriminated against for exercising any of your CCPA rights. However, the CCPA allows us to offer certain financial incentive programs that may result in different prices, rates or quality levels. We currently provide such a program, the Treats customer loyalty program. Treats is free to join and offers you points on purchases and access to member-only deals and discounts. You may withdraw from membership at any time. You can learn more about Treats here.

2020 CCPA Requests - Reporting Metrics:

Request Type	Received	Completed	Denied	Avg Response Time (Days)
Access	32	24	8	14.5
Delete	154	132	22	7.4
Opt Out	1750	1386	364	0.25

Notice of Financial Incentives:

We offer various financial incentives. For example, we may provide discounts, rewards, exclusive offers, or other benefits to customers who sign up to join our Treats loyalty program or to participate in a promotional campaign. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name, email address, or phone number) and commercial information (like your purchase preferences and interests or purchase history). You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you have the ability to opt-out at any time, such as by following the instructions set forth in the applicable promotional campaign or program, or contacting us through one of the methods listed in some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please use the Contact Us information below.

Nevada Residents

We do not sell your name, email address, phone number, address, or other information that identifies you to nonaffiliated third parties. Nevada residents have the right to request that we not sell this information in the future. To make such a request, please use the Contact Us information below.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Email:	Clubdelinternetnet@gmail.com
Mail	Club Del Internet, LLC LLC Attn: Privacy Officer 529 Roseville Ave, Newark, NJ, 07107
Phone	862-234-9696

Do not sell my personal information