Privacy Policy and GDPR

Last Updated: January 20, 2025

1. Introduction
Welcome to ClubDeal.com (“ClubDeal,” “we,” “us,” or “our”). We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website ClubDeal.com and use our services (collectively, the “Services”). We are the data controller for the personal data we process.

For any requests you can contact us via the dedicated CONTACT FORM.

 

2. The Data We Collect About You
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:​

  • Identity Data: Includes first name, last name, username, title, and company.

  • Contact Data: Includes billing address, email address, and telephone numbers.

  • Financial Data: Includes payment card details for subscription purposes.

  • Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, and other technology on the devices you use to access our Services.

  • Profile Data: Includes your username and password, investment interests, preferences, feedback, and survey responses.

  • Usage Data: Includes information about how you use our website and Services.

  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

 

3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including:

  • Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you create an account, subscribe to our service, or request marketing to be sent to you.

  • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment and browsing actions. We collect this personal data by using cookies and other similar technologies.

  • Third parties: We may receive personal data about you from various third parties, such as our KYC/AML verification provider (e.g., VerifyInvestor.com) and analytics providers (e.g., Google Analytics).

 

4. How We Use Your Personal Data & Legal Basis for Processing
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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Purpose/Activity Type of Data Lawful Basis for Processing (including Legitimate Interest)
To register you as a new member Identity, Contact Performance of a contract with you
To process and deliver your subscription, including managing payments Identity, Contact, Financial, Marketing & Communications Performance of a contract with you; Legitimate interest (to recover debts)
To manage our relationship with you Identity, Contact, Profile, Marketing & Communications Performance of a contract with you; Legitimate interest (to keep our records updated)
To enable you to use our platform’s services Identity, Contact, Profile, Technical, Usage Performance of a contract with you
To administer and protect our business and this website Identity, Contact, Technical Legitimate interest (for running our business, provision of IT services, network security)
To deliver relevant website content and advertisements to you Identity, Contact, Profile, Usage, Marketing & Communications, Technical Legitimate interest (to study how customers use our services, to develop them, to grow our business)
To use data analytics to improve our website and services Technical, Usage Legitimate interest (to define types of customers for our services, to keep our website updated and relevant)
 
 
 

5. Disclosures of Your Personal Data
We do not sell your personal data. We may share your personal data with the parties set out below for the purposes set out in the table above:​

  • Service Providers: Such as our KYC/AML verification partner, payment processing providers, and cloud hosting services (e.g., AWS, Google Cloud).

  • Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

  • Regulators and other authorities: Who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

5.1. Artificial Intelligence (AI)

We utilize artificial intelligence and machine learning (“AI”) to enhance our Services. Our purpose for using AI is to:

  • Analyze large volumes of data to identify trends, patterns, and anomalies within documents.

  • Provide you with sophisticated data analysis and due diligence tools.

  • Enhance the security of our platform by detecting irregular activity.

The output of our AI tools is provided to you as insights for informational purposes only. ClubDeal.com does not use AI to make any automated decisions about you that would have a legal or similarly significant effect. All personal data used to train our AI models is anonymized or aggregated to protect your privacy.

5.2. Blockchain and Distributed Ledger Technology

To ensure the integrity, security, and transparency of certain platform activities, we utilize blockchain technology. Our purpose for using blockchain is to:

  • Create a tamper-evident, immutable audit trail for critical actions, such as document uploads and version control.

  • Allow members to cryptographically verify the authenticity and timestamp of deal-related documents.

We are aware of the “right to erasure” under GDPR and have designed our system to protect this right. To achieve this, personally identifiable information (PII) is not stored directly on the blockchain. Instead, we store a cryptographic hash (an anonymized, unique fingerprint) of the data on-chain, while the actual data containing PII is stored securely off-chain. This allows us to delete your personal data from our off-chain systems upon a valid request, effectively severing the link to the non-personal, verifiable record on the blockchain.

Furthermore, our platform operates on a private, permissioned blockchain, meaning access is restricted to authorized participants only, not the general public.

 

6. International Transfers
We may transfer your data outside the European Economic Area (EEA). If we do, you can expect a similar degree of protection in respect of your personal data as we ensure that appropriate safeguards are in place, such as using specific contracts approved by the European Commission (Standard Contractual Clauses).

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7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. These measures include data encryption, access controls, and regular security assessments. The use of blockchain technology provides an immutable audit trail for certain platform activities, enhancing transparency and security.

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8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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9. Your Legal Rights (GDPR)
Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us with the dedicated CONTACT FORM. You have the right to make a complaint at any time to your local supervisory authority for data protection issues.

 

10. Cookies
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can set your browser to refuse all or some browser cookies.

 

11. Changes to This Privacy Policy
We keep our privacy policy under regular review. Any changes will be posted on this page, and where appropriate, notified to you by email.