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Privacy Policy for Metropolitan Club Mobile Application

Last Updated: November 4, 2024

1. Introduction
Welcome to the Metropolitan Club mobile application ("App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. By using the App, you consent to the practices described in this policy.

2. Information We Collect
2.1 Personal Information
We may collect the following categories of personal information as defined by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
  • Identifiers (name, email address, postal address, phone number, IP address)
  • Customer records information
  • Protected characteristics
  • Commercial information
  • Biometric information
  • Internet or other electronic network activity
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information
  • Education information
  • Inferences drawn from personal information
2.2 Automatically Collected Information
When you use our App, we automatically collect:
  • Device type and operating system
  • App usage statistics
  • IP address
  • Access timestamps
  • App interaction data
3. How We Use Your Information
We use the collected information for:
  • Processing membership applications and payments
  • Providing access to club facilities and services
  • Sending notifications about events and promotions
  • Improving our App and services
  • Analyzing usage patterns
  • Addressing technical issues
  • Communicating important updates
4. Information Sharing and Disclosure
As required by California law, we disclose that in the preceding 12 months:
4.1 Categories of Personal Information Sold or Shared
We have not sold personal information to third parties. Under CPRA's definition of "sharing," we share certain information for cross-context behavioral advertising purposes.
4.2 Categories of Third Parties
We share personal information with:
  • Service providers and contractors
  • Third-party payment processors
  • Analytics providers
  • Marketing partners
  • Legal authorities when required by law
5. California Privacy Rights
Under California Civil Code Section 1798.100-1798.199.100 (CCPA/CPRA), California residents have the following rights:
5.1 Right to Know
You have the right to request that we disclose:
  • Categories of personal information collected
  • Sources of personal information
  • Business or commercial purpose
  • Categories of third parties with whom we share
  • Specific pieces of personal information collected
5.2 Right to Delete
You may request deletion of personal information we collected from you, subject to certain exceptions.
5.3 Right to Correct
You may request correction of inaccurate personal information.
5.4 Right to Limit and Opt-Out
You have the right to:
  • Limit use and disclosure of sensitive personal information
  • Opt-out of personal information sharing
  • Opt-out of automated decision-making technology
  • Opt-out of profiling
5.5 Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA/CPRA rights.
5.6 Right to Data Portability
You have the right to request your personal information in a portable format.
6. Exercising Your California Privacy Rights
To exercise your rights: We will verify your identity through our secure verification process which includes:
  1. Verification of your name and member number against our internal database
  2. Completion of 2-factor authentication that was established during your app registration
We maintain these strict verification procedures to ensure the security of your personal information and prevent unauthorized access to your data.
We will respond to verifiable consumer requests within 45 days. If we need more time, we will notify you in writing.
6.1 Authorized Agents
You may designate an authorized agent to submit requests on your behalf. Authorized agents must complete the same verification process, and provide documentation of their authorization to act on your behalf.
7. Notice at Collection
As required by California law, we provide this Notice at Collection of:
  • Categories of personal information collected
  • Purposes for which the information will be used
  • Whether information is sold or shared
  • Retention period for each category
  • Right to opt-out of sale/sharing
  • Right to limit use of sensitive personal information
8. Data Security
We implement reasonable security procedures and practices appropriate to the nature of the personal information to protect it from unauthorized access, destruction, use, modification, or disclosure.
9. Data Retention
We retain personal information for no longer than reasonably necessary for the purposes disclosed in this policy or as required by law.
10. Shine the Light Law
California Civil Code Section 1798.83 permits California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes.
11. Do Not Track Signals
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.
12. Changes to Privacy Policy
We will notify you of material changes to this policy through the App or via email. Your continued use of the App after such notice constitutes acceptance of the changes.
13. Contact Information
For privacy-related inquiries:
Metropolitan Club
640 Sutter Street
San Francisco, CA 94102
Email: [email protected]
Phone: 415-872-7200
Website: www.metropolitanclubsf.org
14. Additional California-Specific Disclosures
14.1 Notice of Financial Incentive
If we offer financial incentives in exchange for personal information, we provide notice and obtain opt-in consent.
14.2 Sensitive Personal Information
We collect and use sensitive personal information only for purposes authorized under CPRA.
14.3 Minor's Data
For users under 16 years of age, we obtain affirmative authorization for the sale or sharing of personal information.
14.4 Accessibility
This privacy policy is available in alternative formats upon request.