Privacy Policy

Effective February 19, 2019 1

The Register Holdings, LLC, its subsidiaries and affiliates (collectively, “The Register”, “we”, “us” or “our”) appreciates your interest in our club and our related club member services, and we are aware that you are concerned as to how the information you provide to us is used and shared with others.  This policy describes the types of information we may collect from you or that you may provide when you submit your membership application or visit the website theregister.io (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  By submitting personal information through the website, you agree to the terms of this Privacy Policy, and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy.

Our Privacy Policy consists of both this website Privacy Policy, and where applicable, the GDPR Privacy Notice. If you are a resident of a country located in the European Union, or the European Economic Area, including Switzerland and the United Kingdom, please refer to our GDPR Privacy Notice which applies to Personal Information on EU residents collected by us. If we transfer personal information concerning EU residents between the European Economic Area (EEA) and the United States, the GDPR Privacy Notice applies.  (See the GDPR Privacy Notice for information on transfers of information from the EEA.)

We have established a comprehensive privacy program, including the appointment of a Chief Privacy Officer, designed to help us respect and protect your data privacy rights.  It describes the types of information we gather, how we use it, and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

What kind of information does The Register collect?

We typically collect two kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you that we automatically collect when you visit our website or that you provide us.

  1. Personal Information: As a general policy, we do not automatically collect your Personal Information when you visit our website. Personal Information means any information relating to an identified or identifiable natural person. Specifically, Personal Information consists of your name, postal address, email address, date of birth, driver’s license number, passport number, financial account information, or other similar information.  We may request, collect, or otherwise provide you an opportunity to submit your Personal Information in connection with certain activities on our website, including but not limited to:
  • Registration screens, online forms, and information you provide when you sign up to use the website
  • Personal information submitted by you as a part of the Club Membership Applicationor Club Membership Agreement
  • Personal information required to be submitted by you as a condition for your access to or receipt of current or future club member services

Our definition of Personal Information means personally identifiable information and includes any information that may be used to specifically identify or contact you, such as your name, address (mailing or email), phone number, etc. and includes Sensitive Information.  We do not knowingly collect Sensitive Information (personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual) when we request Personal Information.  Whether or not you provide this Personal Information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website.

  1. Non-Personal Information: Non-personal information is any information that does not personally identify you.  Non-personal information can include certain Personal Information that has been de-identified; that is, information that has been rendered anonymous.  We obtain non-personal information about you from information that you provide us, either separately or together with your Personal Information.  We also automatically collect certain non-personal information from you when you access our website.  This information can include, among other things, IP addresses, the type of browser you are using (e.g., Chrome, Firefox, Internet Explorer, Safari, etc.), the third party website from which your visit originated, the operating system you are using (e.g., Android, iOS, macOS, Windows 10,  ), the domain name of your Internet service provider (e.g., AT&T, Comcast, Google Fiber, Verizon, etc.), the search terms you use on our website, the specific web pages you visit, and the duration of your visits.

What does The Register do with the Personal Information you provide?

We use the Personal Information you submit to us to:

  • Respond to your requests
  • Communicate club, club services, or membership information that might be useful or urgent in nature, including special events, facilities closures, or changes to the terms and conditions of membership
  • Communicate significant website changes or web content information
  • Provide future service and support

We use non-personal information in a variety of ways, including to help analyze site traffic, understand user needs and trends, carry out targeted promotional activities, and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you.

What about “cookies” and web beacons?

We may automatically receive and store certain types of non-personal information whenever you interact with us. For example, like many websites, we use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”) to obtain certain types of information when your web browser accesses our website. “Cookies” are small files that we transfer to your computer’s hard drive or your Web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you, such as recognizing you as a frequent user of our website. “Web beacons” are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.For more detailed information about cookies, you may wish to visit www.allaboutcookies.org

Examples of the information we collect and analyze in this manner include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; your behavior on our Website, including the URL you come from and go to next (whether this URL is on our site or not); and cookie number.

Children under the age of 18.

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, attempt to apply for membership through the website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [INSERT EMAIL ADDRESS].

Do you use preference-based advertising?

We do not currently share personal information that we collect for preference-based advertising purposes and we do not currently have any plans to do so through this Website.

What are The Register’s security measures?

The Register takes steps we consider reasonable to protect Personal Information collected via this website from loss, misuse, and unauthorized access, disclosure, alteration and destruction.  The Register has put in place appropriate physical, electronic and managerial procedures designed to safeguard and secure the Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction.  Keep in mind, however, that despite such reasonable safeguards, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information.  In the unfortunate event that your Personal Information is compromised, we may notify you by e-mail (at our sole and absolute discretion except where required by law) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

Under what circumstances does The Register share information?

The Register does not sell, trade, or rent your Personal Information to others.  Unless we have your permission or are required by law, we will only share the Personal Information you provide online with affiliates or subsidiaries of The Register and/or business partners who are acting on our behalf to complete the activities described above.  You will be given the opportunity to opt out:  (i) if we decide to share your information with a third party (unless that third party is acting as an agent to perform tasks on behalf of us and under our instructions); or (ii) if it is to be used for a purpose that is incompatible with the purposes for which it was originally collected or subsequently authorized by you. We do not share sensitive information with anyone under any circumstances.

Our business partners and subcontractors receiving Personal Information are required to maintain the confidentiality of any data we provide or that they access in providing their services to us, and to apply security protection measures that are consistent with our promises under this Privacy Policy.  We will ensure that any third party to whom Personal Information may be disclosed agrees in writing to provide an adequate level of privacy protection, and only to share Personal Information with those in their organizations with a need to know.  These companies are authorized to use your Personal Information only for the purposes that we originally instructed, or as authorized by you.

Email CommunicationsWe may share your email contact information with our partners to assist with marketing our products and services.  You mayunsubscribe from receiving future commercialemail communications from us by clicking the “unsubscribe“ link included at the bottom of any marketing emails we send, or by emailing us as provided in the “Contact Us” section below.  However, we reserve the right to send you transactional emails such as customer service communications in connection with any services we provide you. For security reasons, we do not recommend that you send PII, such as passwords, social security numbers, or bank account information, to us by email.

Transfer of Assets:  We do not sell or lease personal information or provide a list of our club members or users to third parties, except as described above.  However, as we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the information we have about you will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Necessity:Notwithstanding anything herein to the contrary, wereserve the right to disclose any information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, or the Website; or (d) in an emergency to protect the health and safety of the Website’s users, The Register’s club members, or the general public.

Links to Websites Outside The Register

This Privacy Policy may contain links to other websites that may be of interest to you. These links are provided as a courtesy of The Register, and it is likely that the owners of these sites have their own privacy policies separate from those of The Register. We suggest that you review these privacy policies before providing personal information.  The Register will have no responsibility or liability for any of these links.

Your Consent

BY VISITING THE WEBSITE, YOU ARE ACCEPTING THE POLICIES THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND CONSENTING TO THE COLLECTION AND USE OF INFORMATION BY THE REGISTER.  WE WILL POST ANY CHANGES TO THIS POLICY WE MAY MAKE FROM TIME TO TIME ON OUR WEBSITE.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITE.

Contact Information

Questions or comments regarding this Privacy Policy should be submitted to our Privacy Officer by e-mail as follows: info@theregister.io.

You can also reach us by U.S. mail:
200 2nd Avenue South
Nashville, TN 37201
Attn: Privacy Officer

Changes to Privacy Policy

This Privacy Policy may be amended from time to time in our sole discretion. The effective date of the Policy may be found on the first page of the Privacy Policy.

GDPR Privacy Notice1

Effective February 19, 2019

Introduction

This GDPR Privacy Notice is a supplement to our Privacy Policy and concerns certain personal data we have collected about residents of the countries in the European Union, consisting of the European Economic Area, Switzerland, and to the extent that the United Kingdom is no longer a member of the European Union, the United Kingdom. It explains why we have that information, how we use and handle it, and your rights to that information, all as required by the European Union’s General Data Protection Regulation (“GDPR”).

What personal data do we hold?

 Information You Provide to Us

We may collect your personal information such as name, postal address, email address, phone number, country of residence, financial accounts, date of birth, driver’s license number, or passport number, and other information that may be necessary for us to comply with legal or regulatory requirements including Anti-Money Laundering (AML) and Know Your Customer (KYC).

Information We Collect from Others

We may receive information about you from our vendors or affiliates or in the context of providing services and support to our club members, such as your personal contact information including your name, postal address, email address, phone number, and country of residence.

Where did we get your personal data?

We collect your personal data when you register on our website and/or submit a membership application or membership agreement. We may also collect your contact information when you provide it by using our Website, as well as your IP address and other information about your activity on our Website, such as what pages you visit.

What is our purpose for holding your personal data?

Our lawful basis for holding your information depends on the circumstances under which we acquired it:

Type of Information Lawful Basis for Processing
Member and prospective member information collected in connection with a membership application or membership agreement For fulfillment of a contract
Member and prospective member information collected for use in marketing additional products and services Consent or Legitimate Interest

 

What we do with your personal data

We use your details so that we can communicate with you by email or phone and inform you of our services, the status of your membership, or questions about payment of your membership account. We may also collect your IP address and details concerning your activity while on our Website in order to understand your interests and preferences.

The personal data we hold is stored and processed securely in line with the information security measures and guidance standard in our industry. We have implemented appropriate technical and organizational measures designed to prevent the unauthorized disclosure of your personal data, taking into account the level of risk associated with the processing of your personal data.

Cross Border personal data transfers

Your personal data may be transferred to and stored at our servers located in the United States. The United States has personal data privacy laws that are different from your country. While the United States has not received an adequacy decision from the European Union Commission, we will ensure that it is protected in a manner that is consistent with how your personal data is protected if it was processed in your country.

What we don’t do with your personal data

We do not pass your information to anyone else apart from our business services partners as necessary to provide you with the products and services you have requested. We do not use any automated systems relating to your personal data.  We do not use your information for profiling.

How long do we keep your personal data?

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or we have obtained your consent.

What are my personal data rights?

You have the following rights concerning your personal data that we hold and process that you can exercise at any time:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct personal data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the personal data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the personal data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the process below.

All of the above requests will be forwarded on to other parties holding and processing your personal data where appropriate.

Who do I contact if I have an issue with my personal data that you hold?

Please contact our Privacy Officer at info@theregister.io.

How do I make a complaint about how my personal data is being held or processed?

If you wish to raise a complaint on how we handle your personal data, you can contact our Privacy Officer as follows:

By Email: info@theregister.io

By Mail:
200 2nd Avenue South
Nashville, TN 37201
Attention: Privacy Officer

If you are not satisfied with our response you can complain to the data protection authority in the country in which you reside.

This GDPR Privacy Notice was last updated on February 19, 2019.