Clubhouse complies with all applicable laws regarding your privacy. Individuals from the European Union ("EU") may only use our Services after providing your freely given, informed consent for Clubhouse to collect, transfer, store, and share your Personal Data, as that term is defined in the EU's General Data Protection Regulation. EU residents may grant that consent directly to Clubhouse, or to your teacher or school/district administrator, if your teacher, school or school district offers Clubhouse to you to advance your education.
In this Policy, “Personal Information” means any information about an identifiable individual or information that can be used to identify an individual, and includes “Personal Data” as that term is defined under the GDPR.
You are responsible for any Content you provide in connection with the Services. We cannot control the actions of anyone with whom you or any other Clubhouse users may choose to share information. Therefore, we cannot and do not guarantee that Content you or any user posts on the Services will not be viewed by unauthorized persons. Although we may allow our users to set privacy options that limit access to certain parts of the Services, please be aware that no security measures are perfect or impenetrable and that we are not responsible for circumvention of any security measures contained on the Services. Clubhouse does not encourage you to make any personally identifiable information (Personal Information) public other than what is necessary for you to use our Services. You understand and acknowledge that, even after removal, copies of Content may remain viewable in cached pages, archives and storage backups or if other users have copied or stored your Content. We will make efforts to remove the Content under our control that is not part of another user's account.
You may request removal of Personal Information (as described below) that you have provided to us by contacting us. We will remove your Personal Information from our database on your request, but this information may remain in our server logs as part of our standard backup procedures, unless prohibited by contract or law. A verified Organization administrator (Verified Administrator) or Organizer may be able to upload and provide information about you to your account; if you would like to remove or amend that information, you may have to contact and work directly with that Verified Administrator or Organizer.
Any improper collection or misuse of Content or other information accessible on the Services is a violation of Clubhouse's Terms of Service and should be reported
How is children's Personal Information treated?We have included some information below related to the Children's Online Privacy and Protection Act ("COPPA"). COPPA requires that online service providers obtain parental consent or provide notice before they knowingly collect personally identifiable information online from children who are under 13 ("under-13 users"). Clubhouse relies on a teacher, school, or school district to obtain verifiable parental consent to provide our services to under-13 users. Pursuant to COPPA, we may collect an under-13 user's name (first name and last initial), date of birth, email address and/or telephone number in order to operate and provide the Services, and we may collect the under-13 user's parent's (or legal guardian's) email address in order to provide notice to the child's parent or guardian that we may contact the under-13 user for the purpose of allowing access to and use of the Services. If Clubhouse does not receive the parent's email address within a reasonable time period, the under-13 user will not be able to receive any messages and his/her Personal Information will be deleted. If an under-13 user's Clubhouse account is inactive for at least twelve months (meaning, the account has not received a message through the Services in that period of time), Clubhouse's policy is to delete the Personal Information. If we learn we have collected Personal Information from an under-13 user other than pursuant to the above, or if we learn that an under-13 user has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible after we have identified it. If you believe that an under-13 user may have provided us Personal Information in violation of this paragraph, please contact us.
In order for an under-13 user to gain access to additional features or services, Clubhouse may employ one or more methods approved by the Federal Trade Commission for verifying parental consent.
While COPPA requires Clubhouse to follow these procedures for under-13 users in the United States, Clubhouse employs the same process to obtain consent for users under 13 years old for users in Canada.
What information does Clubhouse display or collect?When you use the Services, you may set up your personal profile, send messages, perform searches and queries, and transmit information through various channels as permitted by the functionality of the Services. Clubhouse will not display your personal contact information to other users without your permission. If, however, you utilize Clubhouse in an organization that has paid for a School or District Plan, we will share your personal contact information solely with a Verified Administrators chosen by your school or district and verified by Clubhouse. The information we gather from users enables us to attempt to verify user identity, allows our users to set up a user account and profile through the Services, and helps us personalize and improve our Services. We retain this information to provide the Services to you and our other users and to provide a useful user experience. When you update your information, we usually keep a backup copy of the prior version for a reasonable period of time in case you need to need to go back to that version.
Information you provide to usWe receive and store any information you knowingly enter on the Services, whether via computer, mobile phone, other wireless device, or that you provide to us in any other way. With your express consent, you may be able to upload, import or sync contact information from your mobile device (for example, from your address book) to Clubhouse. This information may include Personal Information such as your name, phone numbers, email addresses, photographs, and, in certain circumstances, your school and/or district, class, group, club, team or Organization affiliation (which may be used to validate your account or to provide you with notifications via the Services from a teacher, school and/or district, class, group, club, team or affiliated Organization ("Notifications"), or any other information necessary for us to provide our Services. For under-13 users, we collect a name (first name and last initial), date of birth, district, school, class, email address and/or telephone number, and that under-13 user's parent's email address to provide notice to the parent regarding the Services. You may choose not to provide us with certain information, but then you may not be able to take advantage of many of our features. We use the Personal Information we receive about you to provide you with the Services and also for purposes such as:
- attempting to authenticate your identity,
- responding to your requests for certain information,
- customizing the features that we make available to you,
- suggesting relevant services or products for you to use,
- improving the Services and internal operations (including troubleshooting, testing, and analyzing usage),
- communicating with you about new features
- and, most importantly, protecting our users, sending emergency messages we are directed to send to you, and working towards making sure our Services are safer and more secure.
Information collected automaticallyWe receive and store certain types of information whenever you use the Services. Clubhouse automatically receives and records information on our server logs from your browser including Clubhouse cookie information, the page you requested, and other usage information such as your activity on the Services, the numbers and frequency of visitors to our site and its components (similar to TV ratings that indicate how many people watched a particular show). None of this information constitutes Personal Information. Certain information that is collected automatically, such as device ID, IP address and phone number, and browsing information that is associated with a user will be treated as Personal Information. In addition, for users who are students, teachers or administrators of schools or districts that contract with Clubhouse for paid Plans, Clubhouse may, with the consent of the Verified Administrator in the school or district, obtain information from a third party Student Information System (SIS) provider, which will include basic directory and class roster information, attendance information, class grades, and similar information that is Personal Information.
We also may provide to our partners aggregate information derived from automatically collected information about how our users, collectively, use our site. We may share this type of non-personally identifiable, aggregated statistical data so that our partners also understand how often people use their services as well as Clubhouse.
Mobile applicationWhen users use our mobile application, we automatically collect the Internet Protocol (IP) address, device ID, device type, and what operating system (OS) the user is running.
We collect users' IP addresses whenever they use our mobile application, which provides us with a coarse approximation of the user's location at the city level in order for Clubhouse to, for example:
- provide Organizers with a geo-specific long-code (i.e., generic phone number with a local area code),
- support features such as school selection, sign-in authentication, and
- enable other internal measurement and Services features.
While Clubhouse collects and temporarily stores phone numbers of first-time users under 13 years of age, we will delete the information collected if parental consent is not obtained. If the underage user has signed up for the Services through SMS and then downloaded Clubhouse's mobile application, Clubhouse will have and may use the underage user's phone number:
- to merge the under-13 user's accounts,
- as a back-up method of notification.
If you are located in Canada, you may opt out of receiving marketing messages (including text messages and emails); however, you may still receive text message and email communications that are necessary for the Services or otherwise exempt from anti-spam laws.
Push notificationsWe send notices to you when an Organizer of your class or group has posted something new to your class or group, you are sent a message, or when Clubhouse needs to inform you of something. If you no longer wish to receive such communications, you may turn them off at the device level. If you are a parent of an under-13 user, you always have the choice to no longer allow your child to receive such communications by contacting us. Any user may contact us at if such user no longer wishes to receive communications from the Services.
Clubhouse reserves the right (but does not have the obligation) to remove any Content from the Services at any time, for any reason (including, but not limited to, if we receive claims or allegations from individuals, companies or authorities relating to that Content or if Clubhouse is concerned that you may have breached the foregoing restrictions), or for no reason at all. You, not Clubhouse, remain solely responsible for all Content that you upload, post, email, transmit, or otherwise provide using, or in connection with, the Services, and you warrant that you possess all rights necessary to provide such Content to Clubhouse and to grant Clubhouse the rights to use such information as provided herein.
A pixel is a small amount of code on a web page or in an email notification. As many services do, we (or our agents) may use pixels to learn whether you've interacted with certain web or email content on our Services. This helps us measure and improve our Services and personalize your experience on Clubhouse.
Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. We use local storage to customize what we show you based on your past interactions with Clubhouse.
Clubhouse uses these technologies to deliver, measure, and improve our Services in various ways. These uses generally fall into one of the following categories:
Authentication and security
- To log you into Clubhouse.
- To protect your security.
- To help us detect and fight spam, abuse, and other activities that violate Clubhouse's policies.
To remember information about your browser and your preferences.
For example, cookies may help us remember your preferred language or country that you are in. We can then provide you with Clubhouse content in your preferred language without having to ask you each time you visit Clubhouse. We can also customize content based on your country, such as disabling SMS, or to withhold certain content based on applicable local laws.
Analytics and research
To help us improve and understand how people use our Services.
For example, cookies help us test different versions of our services to see which particular features or content users prefer. We might also optimize and improve your experience on Clubhouse by using cookies to see how you interact with our services, such as when and how often you use them and what links you click on. We may use Google Analytics to assist us with this.
Mobile analyticsWe use mobile analytics software to allow us to better understand the functionality and improve the performance of our mobile software on your phone. This software may collect, store and use information such as how often you use the application, the events that occur within the application, usage, performance data, and where the application was downloaded from. This software may share information it collects with other third parties (1) as part of providing the analytics services; (2) with integrations that advance teaching, school or district services, student learning or achievement, or parent or guardian participation in their child's education or activities; and, (3) to comply with applicable laws.
Will Clubhouse share any of the Personal Information it receives?Clubhouse relies on its users to provide accurate Personal Information in order to provide our Services. We try our best to protect that information and make sure that we are responsible in handling, disclosing, and retaining your data. We neither rent nor sell your Personal Information to anyone. If other Clubhouse users, other individuals or companies whose products you choose to use, have access to your Personal Information (for example, your messaging content), they may use and share that information in ways that Clubhouse cannot, and does not, control. Clubhouse shares your Personal Information in personally identifiable form as described below. Agents and third party service providers Advertising is not permitted on the Services. However, we employ other companies to perform tasks on our behalf and help us provide certain features of our Services, and may need to share your information with those companies in order to provide our Services to you. Some examples of services for which we use agents include sending email or SMS, analyzing data, providing user services, and searching for any security vulnerabilities. These agents may use Personal Information we share with them, for example, to assist us, to provide their services to you and/or us, and to measure and improve the performance of their services. Clubhouse has reviewed the privacy policies and practices of these agents and third party service providers in order to verify that they are capable of complying with Clubhouse's policies and practices, including those related to the collection, use, transfer, confidentiality, security and integrity of user data. As a condition of contracting with Clubhouse, those agents and third-party service providers committed, in writing, to providing at least equivalent privacy and security for your data as does Clubhouse.
Business transfersIf Clubhouse (or substantially all of its assets) is acquired by another company, user information may be one of the assets transferred to or acquired by that company. You acknowledge that such a transfer may occur, and that any acquirer of Clubhouse may continue to use your Personal Information as set forth in this policy. You will be notified via email or some other means of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information (including the right to delete your information). If Clubhouse goes out of business without a successor, Clubhouse would delete your information.
Protection of Clubhouse and othersWe may release Personal Information when we believe in good faith that release is necessary to:
- comply with the law or national security request (for example, responding to a subpoena or other legal process);
- enforce or apply our Terms of Service and other agreements; or
- protect the rights, property, or safety of Clubhouse, our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government request
With your consentYou will be notified when your Personal Information may be shared with agents or companies other than Clubhouse and you will be given the option to prevent the sharing of this information unless Clubhouse determines that not disclosing this to you prior to your information being shared is necessary to comply with applicable laws or legal processes or we are prohibited by law or legal processes from informing you in advance.
Is information about me secure?The security of Personal Information in the school environment is a top priority for Clubhouse.
Clubhouse has protections in place to enhance our users' security, and routinely update these protections. We have administrative, technical, and physical safeguards designed to protect against unauthorized use, disclosure of or access to Personal Information. In particular:
- Our engineering team is dedicated to keeping your Personal Information secure.
- Clubhouse stores its data within an GCS region that is FedRAMP compliant.
- Clubhouse's main database and all backups are encrypted at rest.
- The GCS cloud infrastructure has been designed and managed in compliance with regulations, standards, and best-practices, including HIPPA, ISO 27001, ISO 27017, ISO 27018, SOC 1, SOC 2, SOC 3, PCI DSS Level 1, CSA STAR, FedRAMP, COPPA, FERPA, FIPS 140-2 Validated, HITRUST CSF, Independent Security Evaluators (ISE) Audit, NIST 800-53, NIST 800-171, Sarbanes-Oxley Act (SOX), Cloud Computing Compliance Controls Catalog (C5), Higher Education Cloud Vendor Assessment Tool (HECVAT), SEC Rule 17a-4(f), CFTC Rule 1.31(c)-(d), and FINRA Rule 4511(c), and MPAA.
- All Clubhouse clients use TLS/SSL when communicating with our servers.
Third party servicesYou may be able to access certain third party products through Clubhouse's Services to share content to or from another website or app. These are not Clubhouse products; they are another company's and we do not control their privacy and security practices so only you can decide whether to connect your Clubhouse account with another company's services.
The third party products you choose to use on Clubhouse may need to collect and use your Personal Information in order to provide their services to you; in order to use any products or services offered by anyone other than Clubhouse, you must review and agree to their specific terms and privacy policies.
Our Services may also include access to, among others:
- Workplace productivity apps that allow for the sharing of content, such as but not limited to, Google Docs, Microsoft Office, Dropbox, or Quip; or
- Social media features, such as the Facebook "Like" button, and widgets, such as the "Share this" button or interactive mini-programs that run on our site.
What information can I access and modify?As a Clubhouse account holder, you have access to view and update the following information at your discretion:
- information in your user account (such as your email address),
- Participant names,
- user preferences, and
- content in your account (note that once provided, you may not be able to edit or remove certain types of content, such as messages)
You also have the right to request access to the Personal Information we hold about you in order to verify the Personal Information we have collected in respect of you and to have a general account of our uses of that Personal Information. Upon receipt of your written request to our Privacy Team (contact information below), Clubhouse will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you such as where that information also pertains to another individual or as otherwise required or permitted by law. In such circumstances We will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
How do I delete my account?You can always opt not to disclose information, even though it may be needed to take advantage of certain Clubhouse features.
You are able to add or update certain information on pages, such as those listed in the "What Information Can I Access" section above. When you update information, however, we often maintain a copy of the unrevised information in our records. Certain types of communication you send to other users cannot be removed, such as message content.
You may request deletion of your Clubhouse account by accessing your account online or contacting us. Note, if you are a Participant or Organizer and you request to delete your account, Clubhouse may notify the Organization and the Organizer(s) of the classes and/or groups you are affiliated with of your deletion request. Please note that certain information may remain in our records, server logs and archives after deletion of your account. Clubhouse retains this information for purposes such as diagnosing problems with the service and for auditing legal investigations, but reserves the right to delete this information in accordance with its standard business practices in effect from time to time. Further, information and other content you have provided may remain visible elsewhere to the extent such content was copied or stored by other users.
For under age users with an account that is inactive for twelve months or more (meaning the account has not received a message through the Services in that time), Clubhouse's policy is to disable access to Personal Information associated with that account.
If your or your child's Personal Information changes, or you no longer desire to use our Services, or you would like to rescind permission for Clubhouse to further contact your child, you may review, correct, update, delete inaccuracies, request deletion of your child's information, or amend it by logging into your account and making those changes or contacting us.We will respond to your request as quickly as possible.
We will retain your or your child's information for as long as your account is active or as needed to provide the Services. If you wish to cancel your or your child's account or request that we no longer use your information to provide Services, contact us.Note we will retain and use information, for example, to comply with our audit and legal obligations, to resolve disputes, and to enforce our agreements.
If the information you are requesting to delete was uploaded or otherwise provided by a Verified Administrator of an Organization to which you belong (for example, through CSV or SIS integration), then you must request deletion of that information directly from the Organization. Clubhouse may inform the Organizer(s) and/or Organization(s) you are affiliated with when you request to delete your Clubhouse account.
If your school or school district has paid for a Plan and the school or district chooses to end their contract with Clubhouse for that Plan service you will be able to use Clubhouse's free services. If your school or district subsequently requests termination of all services and deletion of accounts, Clubhouse will offer you the choice whether to continue using Clubhouse, and if so, provide you with control over your Clubhouse account. If in that instance you as a user wish to delete your service we will honor that request.
If we make material changes to the types of Personal Information we collect or how we use Personal Information collected from under-13 users we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's Personal Information.