Privacy

ICLUBcentral is committed to safeguarding your online privacy. Please read the following policy to understand how we will handle your personal information as you make full use of the offerings at our site. This policy may change from time to time, so please check back periodically. This policy will let you know:

1. What personal information is being gathered about you and why
2. How the information will be used
3. Whom the information will be shared with, if anyone
4. From whom other information may be collected
5. What choices you have
6. How you can update or correct your information
7. What security procedures protect your information
8. What cookies are and how they are used
9. What else you should know about your online privacy

If you have any questions regarding this policy or if you worry that ICLUBcentral is not abiding by it, please contact us at privacy@iclub.com.

1. What information we collect and why:

ICLUBcentral collects information in a variety of ways on different parts of the site.

• Registration
  When you register for an account, we ask for your name and email address. We use your email address when we need to contact you regarding your account and we use your name to personalize your experience. All users must select a Username and Password. While this is the only information required to use our Service, the more information that you provide (and the more accurate it is), the better we are able to customize your experience. In addition, when the site is used, we retain your IP address for some period of time.
• Club & User Information
  We give each club and each user the option of storing additional information, including tax identification numbers. Club officers and administrators can view the contact information and tax identification numbers of all club members, if this information is entered, as well as edit this information. Club members and guests cannot edit your contact information, but can view as much information as you wish to allow them to see. (Each user can change these settings under the Preferences menu.) Non-officer, non-administrator club members and guests cannot view your tax identification number.
• Transactions
  Club officers and administrators may enter transactional information, like member deposits and stock purchases, into the club accounting area. All club members can view the transactional data for their club.
• Club Invitations
  When you invite a friend to join your investment club, we ask for the friend's name and email address. We will automatically send this friend a one-time email inviting him or her to join your club, along with a personal message from you. We store this information for the sole purpose of sending this one-time email. You may contact ICLUBcentral to request the removal of this information from our database.

From time to time, we may ask you for personal information, including but not limited to when you enter a contest or promotion sponsored by ICLUBcentral. If you contact ICLUBcentral, we may keep a record of that correspondence. ICLUBcentral also occasionally asks users to complete surveys that we use for research purposes. All other information gathered is optional and is used to publish your member profile for members of your club and others (as you may set in Preferences) to know more about you. We may also use aggregated information to better target advertising to your interests.

ICLUBcentral's primary goal in collecting personal information is to provide you, our member, with a customized experience. By knowing a little bit about you, ICLUBcentral is able to deliver more relevant content, functions, and advertisements, and hence, to better serve you.

2. How the information will be used

Except as otherwise provided in this Privacy Policy and/or at the point at which your personal information is collected, all details of your personal information are kept confidential—ICLUBcentral does not share data on individual clubs or members with third parties. ICLUBcentral does, however, reserve the right to disclose your personal information when,

1. in its sole discretion, it determines that such disclosure is necessary to protect ICLUBcentral or its employees, their rights or property, or to protect the physical safety or health or employees of ICLUBcentral or a member of the general public; or
2. when compelled to by law, subpoena or court order.

ICLUBcentral may from time to time share contact information with the National Association of Investors Corporation (NAIC), also known as BetterInvesting, for purposes of marketing but does not make accounting or transactional records of individuals or individual clubs available to BetterInvesting/NAIC.

ICLUBcentral occasionally examines our members' demographics, interests, and behavior, based on information provided to us upon registration, during promotions, from server logs, or from surveys. We do this to better understand our users. This data is compiled and analyzed on an aggregated basis. ICLUBcentral may from time to time share this aggregated data with business partners or advertisers, but this does not include information that can identify an individual person or club. ICLUBcentral will only retain your personal information for so long as is deemed necessary by ICLUBcentral, unless we have your permission or unless the law provides otherwise.

Our third-party partners ("Partners") may provide selected services on our site. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. Partners' use of your personal information is subject to their own privacy policies and not this privacy policy. We obtain the user's explicit consent before any information is shared with Partners.

3. Who is collecting your information and who has access to it

When you are signing on to ICLUBcentral and when you are asked for personal information by ICLUBcentral, you are sharing that information with ICLUBcentral and BetterInvesting/NAIC only, unless specifically stated otherwise. Officers, administrators, and other club members may also be able to access certain personal information that you choose to make visible to them (such as your name, content that you post, and so on). (To modify what information is available to whom, please set your Privacy Preferences.) ICLUBcentral is not in a position to monitor or control any particular club member's use of that content.

Only authorized employees, mandatories, and agents of ICLUBcentral will have access to your personal information. It is company policy not to look into any individual's data unless asked by that individual, and not to look into any club's data unless asked by an authorized member of the club. If you ask a question about a transaction that you entered, then we will assume that we have your permission to look at your data unless you explicitly request otherwise when asking. We will only access your information without your express permission if this information is urgently needed for the performance of necessary mandates.

4. From whom other information about you can be collected

From time to time, ICLUBcentral may collect information about you from third parties if we have your permission to do so, if the law authorizes such collection, or if we have a serious and legitimate reason to do so and either of the following conditions is fulfilled:

1. The information is collected in your interest and cannot be collected from you by the time at which such information is necessary.
2. The collection from a third person is necessary to ensure the accuracy of the information.

5. What choices are available to you regarding collection, use, and distribution of your information?

ICLUBcentral may, from time to time, send you email regarding our products and services. In addition, if you indicated upon registration or later that you are interested in receiving offers or information from ICLUBcentral and its partners, we or our partners may occasionally send you mail about products and services that we believe may be of interest to you. If you do not wish to receive these mailings, simply tell us when you give us your personal account information or edit your account information to indicate that you no longer wish to receive such offers and mailings.

You also have choices regarding cookies (which are explained in Section 8 below). By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject all cookies, you will be unable to use the parts of the ICLUBcentral service that required registration in order to participate.

ICLUBcentral does not sell or rent user information to anyone. We will notify you at the time of data collection or transfer if your data will be shared with a third party and you will always have the option of not permitting the transfer, unless the applicable law provides otherwise. If you do not wish to allow your data to be shared, you can choose not to use a particular service or not to participate in certain promotions or contests.

6. How you can edit your information

At your request, ICLUBcentral will confirm the existence of your file and communicate to you any personal information concerning you contained in your file at ICLUBcentral. To ensure security, requests for access to or verification of your personal information must be made in writing, with proof of appropriate identification. Your access to the personal information contained in your file will be free of charge. You may change or remove personal information by first signing in and then editing your member profile. (If you have forgotten your password, you may request a new one. For all other problems signing in, please visit our online support area.)

7. What security procedures protect your information

ICLUBcentral takes your privacy very seriously. Our site gives you two options for logging in: regular (faster) and Secure Server (slower). If you choose to log in using our Secure Server option, you will be protected by the Secure Sockets Layer (SSL) protocol, the financial industry's standard for authenticating sites and for encrypting communications between users and Web servers. (You can tell that you are using the Secure Server option when the url address in your browser starts with 'https://' rather than the standard 'http://'.)

SSL cloaks your personal information with powerful encryption during transmission. SSL is the standard used by online banks, brokerages, and consumer retail sites for protection of information. In addition, our security includes two-way data encryption that incorporates digital certificate technology. We support both 40- and 128-bit encryption technologies.

The security level of your session affects the data that you access during that session. If you do not view your accounting data, for example, then it will not be sent over the internet regardless of the security level that you have chosen. Secure Server sessions will be somewhat slower than regular sessions. Regular sessions are as secure as online email transfer and many clubs decide that this is sufficient for viewing their club's transactions.

Our security measures are not limited to online data transmission: we exercise our best reasonable efforts to protect your information offline as well. The computer servers that store your data are secured in locked and monitored facilities, with access restricted to essential technical employees. Temporary access to your personal information is granted only to employees with a specific need-to-know. (For instance, our support staff might need to see past transactions to help you set up or manage accounting.) Our employees are trained to keep your personal data private and are kept up-to-date on our privacy and security policies.

8. What cookies are and how they are used

ICLUBcentral uses cookies to store non-personal information so that we can tailor the service to your preferences. A cookie is a small amount of data sent to your browser from a web server and stored on your computer. Cookies remind us who you are and make it easier to access your account information on our computers. They also help us estimate our number of members and figure out what areas of our service are most popular so that we can continue to improve our offering. We do not store personal information in these cookies.

9. What else I should know about my online privacy

Please note that whenever you voluntarily disclose personal information online, including in your correspondence within your individual groups, that information can be collected and used by others. In short, if you disclose personal information online that is accessible to others, you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your user identification, passwords and any information about yourself. Please be careful and responsible whenever you are online.

Your account information is password-protected so that only you have access to this personal information. We urge you not to divulge your user identification or password to anyone. Remember to log off your computer or close your browser window when you have finished your work to ensure that others cannot access your personal information and correspondence. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we have put in place safety measures to protect the confidentiality of your personal information, ICLUBcentral cannot guarantee or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. This Web site and the ICLUBcentral services are not intended for children under thirteen years of age. We encourage parents and legal guardians to monitor their children's Internet usage and to help us enforce our privacy policy by instructing their children to never provide their personal information on this Web site without their permission.

The ICLUBcentral site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

If we decide to change our privacy policy, we will prominently post our revised privacy policy on this Web site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You have the obligation to review changes in this privacy policy. Your continued use of this Web site and any other ICLUBcentral services after the revised privacy policy has been posted on this site constitutes your agreement to be bound by all such changes. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner.

If you have any questions about the privacy or security of your data on ICLUBcentral, please contact us at:

privacy@iclub.com
+1 248-654-3100
570 Kirts Blvd., Suite 237
Troy, MI 48084