Privacy Policy · The Country C1ub
The House Papers · Document II

Privacy Policy

A private c1ub should keep things private. Here is exactly what we hold, why, and what you can do about it.

Effective November 5, 2026 · Last updated November 5, 2026

The short version

This summary is here to help. The full policy below is the one that counts.

1 Who we are

1.1 This policy explains how The Country C1ub LLC (“the c1ub,” “we,” “us”) handles personal information when you visit thecountryc1ub.com, join or use the C1ubhouse, open our emails or texts, attend our meetings or events, or otherwise deal with us (the “service”). We are the business responsible for (the “controller” of) that information.

1.2 This policy is part of our Terms of Service. Words defined there mean the same here.

2 What we collect

What you give us

From your payment processor

When you buy, our payment processors (currently Fanbasis and Commas) collect your card or payment details directly. We never receive your full card number. They tell us your name, email, the plan you bought, the amount, dates, and payment status (paid, failed, refunded or disputed), and sometimes the card brand, the last four digits and your billing country.

Automatically, when you use the service

From others

3 How we use it

We may combine information we collect about you from different sources for these purposes. We may also create de-identified or aggregate information (for example, “305 members inside”) that no longer identifies you, and use it for any purpose.

4 Your journal

4.1 The journal in your locker is yours. Journal pages are sealed (encrypted) when stored, aren't shown to other members, aren't used for marketing, aren't used to train AI models, and aren't published.

4.2 Our systems open your journal only to show it to you. Our team won't read it, except where you ask us to (for example, to help with a problem), where it's technically necessary to keep the service working or secure, or where the law requires it.

4.3 If you share something from your journal elsewhere in the house (for example as a goal or a post), that shared copy is no longer private.

5 Photographs, faces & AI

5.1 When you upload photographs for a portrait, character, card or sitting, we and our AI image and video providers process them, including the features of your face, only to create the AI likeness work you asked for and to run that feature.

5.2 We do not use your photographs or any facial information to identify or recognise you, to verify your identity, or to track you. We don't sell, lease or trade them, and we don't disclose them except to the providers that create your work, as the law requires, or with your consent.

5.3 Retention. We keep source photographs while the feature you used them for is active for you. We delete them (and ask our providers to delete any copies they hold) when you ask us to, when your membership ends, or in any case within three (3) years of your last interaction with the c1ub, whichever comes first, unless the law requires us to keep them longer. The finished artwork may be kept as described in the Terms (section 20).

5.4 By uploading photographs, you give your written consent to this processing. You can withdraw consent for the future at any time by emailing dani@thecountryc1ub.com.

5.5 Other AI features. Some features (such as house agents and AI-assisted drafting) send the text you enter, and relevant context, to AI providers so they can generate a reply. We use providers whose business terms limit how they may use that data. Please don't put sensitive information into AI features.

6 What other members can see

6.1 Inside the house, other members may see your name, member number, locker, company, recognition and rank, and anything you post in shared rooms (Radio, pins, posts, the Conversations). Leaderboards may show the top places by name and company and redact the rest.

6.2 You can switch on the privacy option in your locker so the room sees a number and a black bar instead of your name.

6.3 Public on the open web: spotlights you submit are published publicly and can be indexed by search engines. Founder letters and other public pages don't name members beyond what their spotlights already publish, unless a member agrees.

7 Who we share it with

We share personal information only as described here:

We do not sell your personal information for money.

8 Cookies, pixels & session replay

8.1 We and our partners use cookies, pixels, tags, local storage and similar technologies to keep you signed in, remember your choices (for example, if you muted the music), measure traffic, understand how the site is used, and measure and target ads. These currently include:

8.2 You can block or delete cookies in your browser settings, use your device's advertising settings, or visit optout.aboutads.info and youronlinechoices.eu. Blocking some technologies may stop parts of the site (like the house key) from working. Our site doesn't currently respond to “Do Not Track” signals.

8.3 Our emails may contain tracking pixels and tagged links that tell us whether an email was opened or a link was clicked.

9 Text messages

9.1 If you opt in to texts, we use your mobile number to send the messages you agreed to. Reply STOP to stop or HELP for help. Message and data rates may apply.

9.2 No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text-messaging opt-in data and consent will not be shared with any third parties, except the service providers (such as our messaging platform and carriers) that deliver the messages for us.

10 How long we keep it

10.1 We keep personal information for as long as we need it for the purposes in this policy: generally, for as long as you're a member or guest and for a reasonable period afterwards so you can come back, plus as long as needed to resolve disputes, prevent fraud, enforce our agreements and meet legal, tax and accounting requirements (for example, payment and tax records are usually kept for up to seven years).

10.2 Photographs are kept as set out in section 5.3. Marketing contacts are kept until you unsubscribe or ask us to delete them, after which we may keep a minimal record so we remember not to contact you.

10.3 The historical record of the c1ub (letters, films and member milestones already published) may be kept as part of the c1ub's archive, subject to section 20 of the Terms.

11 How we protect it

11.1 We use reasonable technical and organisational measures to protect personal information, including encrypted connections (HTTPS), encryption of journal pages at rest, access keys, limiting who on our team can see what, and providers with strong security programs.

11.2 No system is perfectly secure, and we can't guarantee the security of information sent to us. Please keep your key and combination private and tell us straight away if you think they've been exposed. If a breach affecting your personal information happens, we'll notify you and the authorities where the law requires.

12 Your choices & rights

12.1 Wherever you live, you can ask us to:

12.2 Email dani@thecountryc1ub.com from the address on your account. We'll verify that the request comes from you (or someone you've authorised) before acting, and we'll respond within the time the law requires, usually 30 to 45 days.

12.3 Some information we must or may keep, for example payment and tax records, records needed to prevent fraud or enforce our Terms, or content that's already been published or shared with other members. Deleting your information will end your membership, because we can't run a locker without it. We won't treat you differently for exercising your rights, though some features may no longer be available.

13 US state privacy rights

13.1 If you live in a US state with a consumer privacy law (such as California, Colorado, Connecticut, Virginia, Texas, Oregon and others), you may have the rights in section 12 as legal rights, including the right to know the categories and specific pieces of personal information we've collected, the right to delete and correct, and the right to opt out of the “sale” or “sharing” of personal information and of targeted advertising. You may use an authorised agent, and you may appeal a decision we make about your request by replying to our decision email with “Appeal” in the subject.

13.2 Categories, for California. In the past 12 months we have collected: identifiers (such as name, email, phone, IP address); customer records (such as billing details and address); commercial information (plans bought and payment history); internet and network activity (usage, session replay); approximate geolocation; audio, visual and similar information (photographs, recordings); professional information (company and role); inferences (such as interests); and sensitive personal information limited to taxpayer identification numbers for referral payouts. We collect these from the sources and for the purposes in sections 2 and 3, and disclose them to the categories of recipients in section 7.

13.3 We don't sell personal information for money. Our use of advertising pixels and audience tools may count as “selling” or “sharing” identifiers and internet activity for cross-context behavioural advertising under some laws; you can opt out as described in section 12. We don't knowingly sell or share the personal information of anyone under 16. We use sensitive personal information only for purposes the law permits (such as tax reporting), not to infer characteristics about you.

13.4 Nevada residents: we don't sell covered information as defined by Nevada law, and you can email us to register a request.

14 Visitors from the UK, EU & elsewhere

14.1 If UK or EU data protection law (or a similar law, such as Thailand's PDPA) applies to you, we rely on these legal bases: contract (to provide your membership and the service); legitimate interests (to run, secure, improve and promote the c1ub, recognise members and prevent fraud, where those interests aren't overridden by yours); consent (for texts, non-essential cookies where required, and photographs for AI likeness work); and legal obligation (tax, accounting and legal requests).

14.2 In addition to the rights in section 12, you can object to processing based on legitimate interests, ask us to restrict processing, and ask for your data in a portable format. You also have the right to complain to your local data protection authority, although we'd welcome the chance to fix things first.

15 International transfers

15.1 The c1ub is a US company with members around the world, and our team works from more than one country. Our service providers store and process information mainly in the United States. That means your information may be transferred to, and accessed from, countries whose data protection laws differ from yours. Where the law requires, we rely on appropriate safeguards for these transfers, such as standard contractual clauses offered by our providers.

16 Children

16.1 The c1ub is for adults. We don't knowingly collect personal information from anyone under 18. If you believe a child has given us information, email us and we'll delete it.

17 Changes to this policy

17.1 We may update this policy as the c1ub changes. The “Last updated” date shows when. If a change is material, we'll give notice, for example by email or a notice in the service, before it takes effect.

18 Contact

The Country C1ub LLC · Attn: Privacy
Email: dani@thecountryc1ub.com
Mail: 145 SW 13th St, Miami, FL 33130, United States