California Privacy Notice

Effective Date: February 2026

This California Privacy Notice (“Notice”) supplements the Privacy Policy of Private Club Marketing, Inc. (“PCM,” “we,” “us,” or “our”) and applies solely to residents of the State of California, as required by the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”). Any terms defined in the CCPA/CPRA have the same meaning when used in this Notice.

1. Scope

This Notice applies to California residents (“consumers”) whose personal information we collect in our capacity as a business. It supplements — and does not replace — our main Privacy Policy. Where we process personal information on behalf of our clients as a “service provider,” those clients’ own privacy policies govern that processing. This Notice addresses the data we collect and control directly.

2. Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information, organized by the type of individual from whom we collect it:

Website Visitors

• Identifiers: IP address, device fingerprint, visitor ID, cookies
• Internet/Electronic Activity: Pages visited, referrer URL, search terms, on-site interactions
• Geolocation Data: City, state, and country derived from IP address
• Inferences: Browsing patterns and interests inferred from site activity

Contact Form Submitters / Newsletter Subscribers

• Identifiers: Name, email address, phone number, company name
• Professional/Employment Information: Job title, company
• Internet/Electronic Activity: Email opens, email clicks, website visits
• Geolocation Data: City, state, and country from IP on email opens and website visits

ClubCRM Platform Users (Dashboard Operators)

• Identifiers: Name, email address, phone number, job title, profile photo
• Financial Information: Billing information processed via Stripe — PCM does not store credit card numbers
• Professional/Employment Information: Organization, role
• Internet/Electronic Activity: Platform usage data, login history

Contacts Managed in ClubCRM (Club Members/Prospects)

These contacts are collected by our clients via PCM’s platform. Categories include:

• Identifiers: Name, email address, phone number, mailing address, social media URLs
• Professional/Employment Information: Job title, company, enrichment data sourced from Apollo
• Internet/Electronic Activity: Email opens and clicks, website visits, messaging interactions
• Geolocation Data: IP-based city, state, and country
• Inferences: Lead score, lead tier, engagement score, sentiment analysis
• Communications: Email content, SMS/iMessage messages, Instagram direct messages

3. Sources of Personal Information

We collect personal information from the following sources:

• Directly from consumers: Contact forms, account registration, messages, and voluntary submissions
• Automatically: Cookies, tracking pixels, device fingerprinting, and IP geolocation
• From third parties: Apollo (contact enrichment), Meta Lead Ads, Google Search Console
• From client platforms: Website tracking snippets installed on client websites

4. Business and Commercial Purposes for Collection

We collect and use personal information for the following business and commercial purposes:

• Providing, maintaining, and improving our services and the ClubCRM platform
• Email marketing and campaign delivery
• Identity resolution and audience matching
• Contact enrichment
• Analytics, reporting, and performance measurement
• Payment processing
• Security, fraud prevention, and abuse detection
• Advertising attribution (Meta Conversions API)
• SEO analysis and website optimization

5. Categories of Third Parties Receiving Personal Information

We may disclose personal information to the following categories of third parties:

• Cloud infrastructure providers: Amazon Web Services (AWS) — email delivery, hosting
• Payment processors: Stripe
• Advertising platforms: Meta/Facebook — hashed personally identifiable information via Conversions API
• Data enrichment providers: Apollo API
• Geolocation services: Abstract API
• Identity services: ID5
• Communication platforms: Slack — internal alerts only
• Analytics tools

6. Sale and Sharing of Personal Information

Sale: PCM does not sell personal information as defined under the CCPA/CPRA.

Sharing: PCM does share personal information with Meta via the Conversions API for the purpose of cross-context behavioral advertising. Under the CPRA, this transmission constitutes “sharing” of personal information. Consumers may opt out of this sharing as described in Section 7 below.

7. Your Rights Under the CCPA/CPRA

If you are a California resident, you have the following rights regarding your personal information:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share your information.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. Because PCM shares data with Meta via the Conversions API, you may exercise this right by contacting us using the information below.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit the use and disclosure of your sensitive personal information to what is necessary to perform our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you services, charge you different prices, provide a different level of service, or suggest that you will receive a different level of service for exercising your rights.

Opt Out of Tracking & Sharing

Use the controls below to exercise your right to opt out of non-essential tracking and the sharing of your personal information for cross-context behavioral advertising on this website. Your preferences are saved to your browser and take effect immediately.

How to Submit a Request

For requests that cannot be handled through the self-service controls above, please contact us at privacy-ccpa@privateclubmarketing.com or call 949.743.5793.

Authorized Agents

You may designate an authorized agent to submit a request on your behalf. Authorized agents must provide a valid power of attorney or written authorization signed by the consumer, along with proof of the agent’s identity. We may contact you directly to verify the request.

Verification Process

When you submit a request, we will verify your identity by matching information you provide against information we already maintain. The level of verification required depends on the type of request and the sensitivity of the information involved. We may ask you to provide your name, email address, and other identifying details to complete verification.

Response Timeline

We will acknowledge receipt of your request within 10 business days and provide a substantive response within 45 calendar days. If we require additional time, we will notify you and may extend the response period by an additional 45 calendar days (90 days total).

8. Sensitive Personal Information

PCM may collect the following categories of sensitive personal information:

• Precise geolocation data (derived from IP address)
• Account login credentials (username and password for ClubCRM platform access)

You have the right to request that we limit the use and disclosure of your sensitive personal information to what is reasonably necessary to perform the services you have requested or as otherwise permitted by law.

9. Data Retention

We retain personal information for the periods described in our main Privacy Policy. Retention periods vary based on the type of data, the purpose of collection, and our legal obligations.

10. Summary Table

The following table summarizes the categories of personal information collected, sources, purposes, and third-party recipients:

Contact Us

If you have questions about this California Privacy Notice or wish to exercise your CCPA/CPRA rights, please contact us:

• Email: privacy-ccpa@privateclubmarketing.com
• Phone: 949.743.5793