Last updated November 7, 2024

Thank you for using Clubhouse!

Clubhouse is a social network based on voice. Our products include our iOS and Android apps and our website (our "Products”). Among other things, our Products allow you to use your voice to interact with others in real-time through “Conversations” (what we call the different types of audio conversations, including “Chats,” “Live Rooms,” and “VMs,” you can have using our Products), and to share recordings of those interactions for others to enjoy (or participate in) later.

When you use our Products, you provide personal information to us. We wrote this privacy policy (the “Privacy Policy” or “Policy”) to help you understand what personal information we collect, how we use it and disclose it, how long we retain it, and what choices you have about it. This Policy does not cover information that does not identify you. Nor does it cover the practices of Clubhouse users. Users who listen to you speak on Clubhouse, or view information you share on Clubhouse, might save that information outside of our Products using other tools.

You may have specific privacy rights in your state or region. In the United States, residents of California and other states have specific privacy rights. Residents of the European Economic Area (“EEA”), the UK, Brazil, the Republic of Korea, and other jurisdictions also have specific rights

• Residents of California can find our California Consumer Privacy Act disclosures here.
• Residents of the EEA, the UK, and Brazil can find our Notice to EEA, UK, and Brazilian Data Subjects here.
• Residents of Europe who are not Clubhouse users can find our Non-User Data Notice here.

These additional disclosures supplement, and should be read together with, this Privacy Policy.

Table of Contents

Information We Collect

How We Use The Information We Collect

How We Disclose The Information We Collect

How Long We Keep Information

Managing Your Information

Transferring Information

Revisions

Contact Us

California Consumer Privacy Act Disclosures

Notice to European and Brazilian Data Subjects

Information For European Data Subjects Who Have Not Used Our Products

Custom Voice Privacy Notice

Data Processor List

1. Information We Collect

A. Information You Provide

When you use Clubhouse, we collect personal information that you provide to us. This includes:

Account Information

When you set up an account, we may ask you to provide information about yourself, including your name, phone number, email address, and date of birth. If you use our Products as a guest without setting up an account, we may ask you to provide your name, phone number or other information.

Biographical Information

We may also ask you to provide us with some additional personal information about you that will be visible in our Products, such as topics that interest you (“Interests”), a profile picture, and a bio in your profile to tell others more about you. When you change your profile picture we store a copy of the new picture you upload and retain all profile pictures you uploaded previously for trust and safety purposes and in accordance with our data retention policies.

Social Media And Contact Information

You may choose to connect your other social media accounts, or sync your contacts.

B. Information We Get When You Use Our Products

When you use our Products, we collect additional personal information based on your activity and other personal information you might choose to provide. This includes:

Audio Conversations

• Chats. Chats are audio conversations you can have on Clubhouse that occur asynchronously with other users, and which may also contain attachments like links or images. With Chats, the content you create can be shared with groups of users or user networks more publicly. (As detailed in our Terms of Service). Chats will appear in other users’ “feeds” and in other parts of the app, and in some cases may be shared by other users outside of Clubhouse. Chats are shared with others according to the privacy settings of the user that created the Chat (the “Chat Creator”). This means you can share Chats you create with other users. We retain your Chats indefinitely, unless you delete them, so that they can be played back by other users. A full Chat conversation may be deleted by the Chat Creator, or a specific audio comment (a section of an audio Chat or VM) within a conversation may be deleted by the person who created it. A “House” is a community you can join with users, where you can participate in Chats and Live Rooms, and interact in different ways.
• Voice Messages (“Messages” or “VMs” ). Direct voice messages, which we call “Messages” or “VMs” are voice conversations allowing you to send audio content directly to one person or a group of people (unlike Chats, which are voice conversations that you may share in your feed to groups of users, such as your friends, friends-of-friends, or other House members ). These conversations may also contain attachments like links or images. For VMs, content is recorded and remains available unless a conversation participant deletes a specific item of content (such as a segment) they have created. If you start a VM, or participate in a VM with one or more users, those users may appear in the “Recently Chatting With” section of your profile, which will be displayed to your friends. Friends who visit your profile may press on a user’s photo (or group of user photos) that is displayed in the “Recently Chatting With” section to start a separate, new group conversation with you and the other user(s).
• Live conversations (“Live Rooms”). Live Rooms are conversations where you interact with other users in real time using your voice and other features provided within Live Rooms.
• We record all Live Rooms so that we can investigate any complaints regarding violations of our Community Guidelines or our Terms of Service, or otherwise illegal or illicit activity. This is part of our commitment to users under our Terms of Service to work to provide a safe space for their Conversations and combat illegal and harmful conduct and content. If we receive a complaint while the Room is live, we will review the recording to determine whether a violation has occurred. We will retain the recording as long as reasonably necessary to identify and investigate potential violations.
• In Live Rooms that are open to all users, we may also generate transcripts of the Conversation to analyze the contents of the Conversation and use that information to personalize our Products (“Transcripts”).
• Replays. We record conversations that occur in Live Rooms and make them available to other users where the Room creator instructs us to do so by enabling the “Replay” feature. When Replays are enabled, the recording will be stored by Clubhouse and may be made available to other users on Clubhouse at the Room creator’s instruction. Replays may also be available outside of Clubhouse.

Usage And Activity Information

We collect information about when and how you use our Products. Among other things, this includes Transcripts of Conversations; information about Conversations; Conversations you create; Conversations you participate in; Conversations you join; and Replays you create. It also includes who you follow, what Houses or communities you create or join, web pages you visit, links you share, content you share to other platforms through integrations (i.e. social sharing), queries you submit, and what kind of content you’re interested in.

Text Messages

We store text-based messages you send to and receive from other users and information about those messages, including the messages you send via Room Chat or other messaging features in the Products, including historical Backchannel conversations. We review the contents of these messages if a user reports, or we otherwise detect, a potential trust and safety violation or potentially illegal or illicit activity.

Other Communications

We collect information about the messages you send us when you contact us with questions or feedback, including the contents of those messages.

Contacts

If you give us permission to sync your contacts, we will store identifiers known as hash values derived from the phone numbers of your contacts, and we will update your contacts periodically. Similarly, if you invite somebody to join Clubhouse, we will store a hash value derived from the phone number you provide. We do not collect names, email addresses, or any other information associated with your contacts.

Voice Samples And Text-To-Speech Functions

We may offer a text-to-speech function that lets you convert text into speech to share in Conversations. If you enable this function, we may ask you to provide voice samples, which we will collect and store to create a “Custom Voice” associated with your profile. Depending on your location, applicable laws may define the data used to create your Custom Voice as a biometric identifier or biometric information. Please review our Custom Voice Privacy Notice for details.

Log Data And Device Information

We may collect information from and about the devices you use. In particular, we may collect information about log-in authentication attempts and successful authentications, your hardware and software, such as the hardware model, operating system version, device memory, unique application identifiers, apps installed, unique device identifiers, browser type, and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

Cookie Information

We use cookies (small text files sent by your computer each time you visit our website, unique to your Clubhouse account or your browser) to get log data. Some of these cookies are used to help us understand how you use our Products, how many people use our service, and how they use it. Other cookies are used to help us track the efficiency of our advertising campaigns on other platforms. For more detailed information about cookies, please see our Cookie Policy.

Web and Logged-out Activity

If you visit any web pages on Clubhouse, with or without being logged into an account; or, if you participate in Clubhouse features or create content as a guest (i.e., where we do not require you to log in or have a registered account), we may collect and retain information associated with you, including identifiers such as your name or phone number, device information, session information, details of your activity, cookies, or other information.

C. Information From Third Parties

Social Media Information

If you link your Clubhouse account to X (Twitter), Instagram, or any other social media services, we may receive information from those other services. The information we receive will depend on the privacy settings on those other services.

Service Providers

We may also receive information about you from our service providers.

D. Information About Guests

We may allow you to use our Products to a limited extent without opening an account, such as by allowing you to join a Conversation (which may include a Chat or a Live Room) or a House for a limited amount of time using a link, contributing audio content to a Conversation, or accepting invitations for Conversations scheduled for a future date. By choosing to use our Product without an account, you agree that you will comply with our Terms of Service Community Guidelines, and any other policies Clubhouse makes available in order to maintain the safety of our Products. We will only allow you to do so if you agree to our Terms like any other user must. Similarly, all provisions of our Terms, our Privacy Policy, and our Community Guidelines apply to you the same as they do for any other user.

E. Information About Non-Users

Clubhouse users may sync their contact lists to Clubhouse in order to help Clubhouse connect them to existing users, invite new users, and to connect users and their contacts with one another on Clubhouse. Similarly, users may send people invitations through various methods, including manually entering a telephone number, posting an invitation, and sharing a link. In either case, the only information Clubhouse stores is a hash value derived from the phone number. Clubhouse does not collect names or any other information associated with your contacts, and we do not share the hash values we collect or make them available to others.

For more information, please review our Non-User Data Notice.

2. How We Use The Information We Collect

We use the personal information we collect to provide our Products to you and to improve them. Specifically, we use the data we collect to:

• Register your account, verify your identity (e.g., checking that your phone number belongs to you), and verify the accuracy of your information.
• Develop, operate, improve, maintain, and protect our Products.
• Personalize our Products.We personalize our Products in a number of ways. For example, we may suggest Conversations for you to join, other content you may want to engage with, or users to follow. For more information on personalization, see our Personalization FAQ.
• Send you communications. For example, we may use email, text messages, or app-based notifications to respond to support inquiries, share information about our Products, and tell you what’s happening on Clubhouse.
• Verify and enhance the safety and security of our Products.
• Verify and analyze user engagement, trends, and usage.
• Assess the efficiency of our advertising campaigns on other platforms.
• Handle and record user rights requests, including opt-ins and opt-outs.
• Prevent fraud or other unauthorized or illegal activity.
• Enforce, investigate, and report conduct violating our Terms of Service Community Guidelines, or other policies.
• Respond to requests from law enforcement agencies or other government agencies, and comply with legal or regulatory requirements.

3. How We Disclose The Information We Collect

We do not sell personal information about our users. We may, however, disclose that information to:

Other online services you connect to your Clubhouse account.

If you choose to link your Clubhouse account to X (Twitter), Instagram, or any other services, we may disclose information to those other services at your direction when using our Products.

Services we use to market Clubhouse

When we market our Products we may disclose information to the websites and apps we use to market our Products, including Facebook, Google, X (Twitter), Microsoft, LinkedIn, Trade Desk, or others.

Service providers and other third parties

We employ third parties to process information on our behalf based on our instructions and for the purposes described in this Privacy Policy, including providers of services relating to cloud computing, analytics, security, enforcement of content policies (including our Community Guidelines), and user support.

Law enforcement or governmental or non-governmental organizations

If we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights or property of the public, any person or Clubhouse; or to detect, prevent or otherwise address illegal conduct, fraud, security or technical issues, we may disclose information to law enforcement agencies, other governmental agencies, or private parties as needed.

Our wholly owned subsidiaries and affiliates

If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we would disclose your information to parties involved in such a process (for example, a purchaser).

4. How Long We Keep Information

We keep your personal information only for as long as we reasonably need it to provide our Products to you and fulfill the purposes described in this Policy. This is also the case for anyone that we disclose your personal information to and who carries out services on our behalf. In general, this means we will retain your personal information for as long as you have a Clubhouse account.

For users located in the EEA, the UK or Brazil, you’ll find specific data retention periods for the different purposes of processing under Justifications for Data Processing in the Notice to European and Brazilian Data Subjects.

We may delete some personal information earlier based on changes to your account settings, such as if you instruct us to delete your Contacts. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll remove any information that can identify you from our systems.

As explained above, we record conversations in Live Rooms so that we can investigate any complaints we might receive relating to violations of our Community Guidelines, our Terms of Service, or otherwise illegal or illicit activity.We will retain the recording as long as reasonably necessary to identify and investigate potential violations.  When we generate Transcripts for Live Rooms that are open to all users, we will retain those Transcripts for as long as we need them to personalize our Products.

We also record Conversations and make them available to other users where the creator instructs us to do so. For Chats, content is recorded and remains available to other users according to the Chat creator’s preferences, unless the Chat creator deletes the entire Chat conversation, or a conversation participant deletes a specific item of content (i.e., an audio comment) they have created. For VMs, content is recorded and remains available unless a conversation participant deletes a specific item of content (i.e., an audio comment) they have created. For Live Rooms, the Room creator can opt to record the content of the Room by enabling the “Replay” feature. When Replays are enabled, the recording will be stored by Clubhouse and may be made available to other users on Clubhouse or other people outside of Clubhouse. Replays are created and saved at the direction of Room creators, and remain available unless the Room creator instructs us to remove the Replay.

If an item of content is deleted by its creator, we may retain a copy of it temporarily in storage, but will delete it from our backups within a reasonable amount of time.

5. Managing Your Information

There are a variety of ways you can manage the personal information we have about you. Specifically, you can:

• Request access to the information we collect and hold about you. We'll aim to provide this to you within 30 days after you submit your request through our Privacy Center.
• Have your information corrected or deleted. You can update your information in your profile, delete individual Chats you have created, delete Chat and VM audio comments you created within Conversations, and delete Replays you have created. You can delete your information within our Products, by deleting your account in your account settings, or by making a written request to our team, depending on the type of information you are requesting to delete. Because Clubhouse involves people creating audio together, the details of this are helpful to understand. You can learn more about these details by visiting our Knowledge Center.
• Change your profile settings. If you want to restrict the availability of certain information in your Clubhouse profile, you can do so in your account settings page. Details about “private profiles” and privacy settings can be found in our Knowledge Center.
• Disconnect social media accounts. When you connect your social media accounts to Clubhouse, we notify those platforms. You may disconnect your social media accounts directly within the Products at any time via your account settings page.
• Delete your contacts. If you chose to sync your contacts, you can always change your mind by disabling contact sync in your account settings page.
• Opt out of push notifications. If you opt in to receive push notifications within the Products, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the Products, or deleting the Clubhouse app from your iOS or Android device.
• Pause or reduce notifications. If you want to pause notifications for a while, or reduce the number of notifications Clubhouse sends you, you can do so in your account settings page.
• Disable optional recording features. Creators of a Room or moderators of a Room may disable Replays.
• Revoke consent you have given or object to us processing your information. You can revoke any consent you have given us by adjusting your settings, or object to processing personal information in certain circumstances.

To use these tools please visit your account settings, our Knowledge Center, or your device settings.

6. Transferring Information

While our Products are offered worldwide, we are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. When you use our Products, your personal information may be transferred and stored outside your home country, including in the United States, for the purposes described in this Policy. The privacy protections and the rights of authorities to access your personal information in such countries may not be equivalent to those of your home country. For European Data Subjects, more details are provided in “Storage and Transfer.”

7. Revisions

We may change this Policy from time to time. If we do, we’ll post any changes on this page. We will provide a more prominent notice or get your consent where required by law.

8. Contact Us

The best way to manage personal information about you as described above or get in touch with us is through your account settings or via our Knowledge Center.

Alpha Exploration Co. (doing business as “Clubhouse”) is responsible for your information. You can contact Clubhouse at 548 Market Street PMB 72878, San Francisco, California 94104, USA.

California Consumer Privacy Act Disclosures

Last Modified: November 7, 2024

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties to whom we disclose it, which we have explained above. This notice supplements information contained in our Privacy Policy and applies solely to residents of the State of California (“consumers” or “you”).

Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception under the CCPA applies. You can download a pdf version of the notice and policy here.

1. Your Rights To Access And Deletion

Access. You have the right to request a copy of the personal information we collect, use, or disclose about you. You can submit a request for this information via our Privacy Center.

Deletion. You also have the right to request the deletion of personal information. You can submit a request for the deletion of personal information via our Knowledge Center using this form. Alternatively, you can send your request to us at the address noted in Section 6 of this Disclosure.

Correction. You can ask us to correct the personal information that we hold about you. You can submit a request for correction via our Knowledge Center using this form.

Verification. Clubhouse may ask you to provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Clubhouse will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

Exceptions. In accordance with the CCPA, Clubhouse will not provide the following information in response to access requests for the following reasons:

• Account data such as account passwords and identity verification codes, unmasked phone numbers, or email addresses, because of the sensitive nature of the information.
• Other users’ and employees’ personal information, including the names and account information of individuals who may have invited you to the app, other users’ feedback, and employees’ comments because the information belongs to other individuals and disclosing it may impact their rights.
• Internal proprietary attributes that enable us to provide various aspects of our app, including channel and room customization, suspension decisions, and content suggestions, because the information is protected by federal and state trade secret law.
• Server logs that are older than 30 days because we use these to ensure the security and integrity of our app.

Clubhouse does not sell the personal information of its users. When a business sells your personal information, you have a right to opt out. Clubhouse does not sell, and in the preceding 12 months did not sell, California residents’ personal information. Clubhouse does not have actual knowledge that it sells the personal information of minors under 16 years of age. All users under 18 are defaulted into a “private profile.”

2. Personal Information Handling Practices

Below you will find a list of the categories of personal information we collect about California residents and have collected in the preceding 12 months. For each category of personal information we have collected, we reference the category or categories of personal information in the CCPA that most closely describe the personal information.

Personal Information Handling Practices

Clubhouse collects this personal information from the following sources:

• Information Provided By You. When you use Clubhouse, we collect personal information that you provide to us. When you set up an account, we may ask you to provide information about yourself, including your name, phone number, email address, and age (“Account Data”). We may also ask you to provide us with some additional personal information that will be publicly visible in our Products, such as a profile picture, a bio in your profile to tell other Clubhouse users more about you, and topics you’re interested in. You may also choose to connect your other social media accounts, sync your contacts.
• Information We Get From You When You Use Our Products. When you use our Products, we collect additional personal information based on your activity and other personal information you might choose to disclose. As discussed in our Privacy Policy, this may include usage and activity information, audio information from Conversations, messages, other communications, transaction data, contacts, log data and device information, and cookie data. Clubhouse may collect information from the computer, tablet, phone, or other device that you install our mobile application on, that you use to access our Products, or that you use to open an email or click on an advertisement from Clubhouse. Clubhouse does not respond to “do not track signals.”
• Information From Third Parties. If you link your Clubhouse account to X (Twitter), Instagram, or any other social media services, we may receive information from those other services. The information we receive will depend on the privacy settings on those other services. We may also receive information about you from our service providers.

Clubhouse collects, uses, retains, and discloses this personal information for the following purposes:

• Register your account, verify your identity, and verify the accuracy of your information.
• Develop, operate, improve, deliver, maintain, and protect our Products.
• Personalize our Products by suggesting Live Rooms, Houses, and other content we think you might be interested in, or by prompting you to create content or Conversations. We also use this information to (i) suggest users you might like to follow; and (ii) suggest your profile to other users.
• Send you communications via email or text message. For example, we may use email or text messages to respond to support inquiries, disclose information about our Products, highlight content we think you might like, tell you about features we think you might like to hear about, or suggest ways to improve your Clubhouse experience.
• Verify and enhance the safety and security of our Products
• Verify and analyze user engagement, trends, and usage
• Assess the efficiency of our advertising campaigns on other platforms
• Handle and record consumer rights requests, including opt-ins and opt-outs
• Prevent fraud or other unauthorized or illegal activity
• Enforce, investigate, and report conduct violating our Terms of Service, Community Guidelines, or other policies
• Respond to requests from law enforcement agencies or other government agencies, and comply with legal or regulatory requirements.

3. Disclosure Of Personal Information

In the preceding 12 months, Clubhouse disclosed the above categories of personal information to the following categories of third parties for a business purpose, in some cases as directed by you:

• Third parties and service providers that provide products or services to us. In particular, companies that help us support our Products or provide services to you. Clubhouse may use third parties or service providers to process information on our behalf based on our instructions and for the purposes described in the Privacy Policy, audit interactions and transactions with you, address security, fix errors, maintain accounts and provide customer service, assist with our internal research, and verify service quality or safety.
• Other online services you connect to your Clubhouse account. If you link your Clubhouse account to X (Twitter), Instagram, or any other services, we may disclose your information to those other services at your direction when using our Products.
• Government regulatory authorities. We may disclose your personal information to relevant government regulatory authorities if we believe the disclosure is reasonably necessary to comply with a law, regulation; protect the safety, rights or property of the public, or any person or Clubhouse; or to detect, prevent or otherwise address illegal conduct, fraud, technical or security issues.

4. Non-Discrimination

Clubhouse will not discriminate against you if you exercise your privacy rights.

5. Authorized Agent

In addition to exercising your rights yourself, you may also designate an authorized agent to make these requests under the CCPA on your behalf. In order to do this, we may ask you to verify the request directly using the phone number or email address connected to your account, or via other means. The information Clubhouse asks you to provide to verify your identity may depend on your prior interactions with us and the sensitivity of the personal information at issue.

6. Contact Information

If you have any questions or comments about this notice and policy, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us via our Knowledge Center, or at the following address:

Alpha Exploration Co. Inc.

548 Market Street PMB 72878

San Francisco, California 94104

USA

Thank you for using Clubhouse!

Notice to European and Brazilian Data Subjects

Last updated November 7, 2024

This privacy notice (“Notice”) supplements the Privacy Policy with additional information for EU and UK data subjects pursuant to EU and UK data protection laws (“GDPR”), and for Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”). For a full description of how we use your Personal Data, you should read this notice together with the Privacy Policy.

Controller and Representative. Alpha Exploration Co. (trading as Clubhouse) is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “Contact Us” section listed in our Privacy Policy.

We have also appointed representatives in the EEA, Switzerland and the UK. If you are located in the EEA, Switzerland or the UK, you can contact the relevant representative about our processing of your personal data:

• EEA and Switzerland: VeraSafe Ireland Ltd., which you can contact:
• by email: article27@verasafe.com
• by post: Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23AT2P, Ireland;
• UK: VeraSafe United Kingdom Ltd., which you can contact:
• by email: article27@verasafe.com
• by post: 37 Albert Embankment, London SE1 7TL, United Kingdom

Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Information We Collect” section in our Privacy Policy above (including personal data we may receive from third parties – see “Information From Third Parties” section above), and how we use it in the “How We Use The Information We Collect” section above.

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

We can collect personal data of minors under 18, who in any case are of age under applicable privacy law (i.e. we only collect data of minors aged 16).

Justification for Data Processing. EU, UK, and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities.  Clubhouse generally relies on one or more of the following justifications to process personal data:

• Contractual Necessity, to provide you with the Products in accordance with our Terms of Service or otherwise perform a contract we have entered into with you or are about to enter into with you.
• Legitimate Interests, where it is necessary for our legitimate business purposes, your interest or the interests of a third party, and your interests and fundamental rights do not override those legitimate interests.
• Consent. Where we rely on your consent to process personal data about you, you have the right to later withdraw your consent in the manner indicated when you consent or by contacting us as described in this Privacy Policy.
• Legal obligation, where we need to comply with a legal obligation to which we are subject.

The table below sets out a description of all the ways we use your personal data, and which of the justifications we rely on to do so. We have also identified what our legitimate interests are where we rely on that justification for processing. Note that provision of some of the following data is necessary to establish an account on Clubhouse.

Justifications for Data Processing

Recipients of Data. We may disclose your personal data to the recipients described in the “How We Disclose The Information We Collect” section in our Privacy Policy above. You can find an up-to-date list of the third party service providers we employ to process personal information on our behalf here.

Retention of Data. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For further information, please see the "How Long We Keep Personal Information" section  and “Data retention period” in the section “Justification for data processing”in the  Privacy Policy.

Storage and Transfer. We are based in the United States and rely on third-party cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We may also use third-party service providers located outside of the EU or the UK. If we transfer your personal data out of the EU or the UK, we take measures to protect the confidentiality and security of your personal data, and your rights as a data subject.

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further information, you can review EU adequacy decisions here, and you can review UK adequacy decisions here.
• If we transfer your personal data to a country that is not deemed to provide an adequate level of data protection, in order to protect your personal data we may use contractual clauses approved for use in the EU and/or UK in accordance with the EU and/or UK data protection regime(s).

If you fail to provide personal data. Where we need to collect personal data by law, or to perform our contractual obligations to you under the Terms of Service, and you fail to provide that data when requested, we may not be able to provide our Products to you.

Your Rights. The GDPR and the LGPD grant EU, UK, and Brazilian data subjects the following rights:

• Access. You can request a copy of the personal data that we maintain about you. If you require additional copies, we may need to charge a reasonable fee.
• Deletion and Correction. You can ask us to delete or correct the personal data that we hold about you. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to delete your personal data to comply with local law. We may not always be able to comply with your request for deletion for specific legal reasons which we will tell you about at the time of your request.
• Objection to Processing. You may have the right to object to how we use your personal data. For example, this may apply where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.
• Restrict Processing. You may ask us to suspend our processing of your personal data in the following scenarios: (i) if you want us to establish its accuracy, (ii) if our use of the data is unlawful but you do not want us to erase it, (iii) if you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Portability. If required to do so, on your request, we will give you your personal data in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdrawal of Consent. Insofar as we rely on consent as the lawful basis on which we process your personal data, you can withdraw your consent to process that personal data at any time. This will not, however, affect the lawfulness of any processing carried out before you withdraw your consent, or the processing of any personal data for which we rely on a basis other than consent.

To exercise these rights, please email privacy@clubhouse.com, or visit http://support.clubhouse.com. In addition to contacting Clubhouse as your data controller, you may also contact our representative using the contact information referenced in the “Controller and Representative” section above. You also have the right to complain to a data protection authority in your country about our processing of your personal data.

Thank you for using Clubhouse!

Information For European Data Subjects Who Have Not Used Our Products

Last updated September 6, 2023

Non-User Data Notice

If you have not set up an account, or used our Products as a guest after agreeing to our terms and conditions, (a “Non-User” or “you”), Clubhouse may process your phone number if a Clubhouse user has your phone number saved in the contact list stored in their device and chooses to share those contacts with Clubhouse, or sends you an invitation by typing in your phone number. This Notice provides information about our use of Non-User data to data subjects in the EU and the UK.

What information about Non-Users does Clubhouse store?

As noted in our Privacy Policy, Clubhouse users can choose to sync their contacts. This allows us to help Clubhouse users connect with people they might know, and to invite new people to Clubhouse more easily. Similarly, a user may choose to send an invitation to a specific person entering that person’s phone number. This could be an invitation to join Clubhouse, or an invitation to join a specific House or Room that the user thinks you might be interested in. If you are listed in the contacts of a Clubhouse user who chooses to sync contacts, or a user decides to send you an invitation by entering your phone number, we may process your phone number even if you are not a Clubhouse user.

Either way, Clubhouse does not store your phone number in a readable format. Instead we generate a cryptographic hash value derived from your phone number, and update this information from time to time. We store the hash value in a list linked to the Clubhouse user who chose to sync contacts or send an invitation. Clubhouse does not collect names or any other information from a user’s contacts.

What does Clubhouse do with Non-Users’ Information?

We use the hash values derived from phone numbers to help users connect with one another on Clubhouse (now or later), suggest people to invite, and send invitations. If you join Clubhouse, we will use the hash value derived from your phone number to help other Clubhouse users connect with you on Clubhouse.

Does Clubhouse Disclose Non-User information to third parties?

Clubhouse does not disclose Non-User information to anyone other than our users and our third-party service providers.

What is Clubhouse’s legal justification for processing this information?

We rely on our legitimate interests and the legitimate interests of our users and Non-Users. More specifically, we rely on our legitimate interests in personalizing the Clubhouse Products by connecting users with people they may know on Clubhouse. We rely on the interests of our users in more efficiently connecting with people they may know on Clubhouse, and their interest in inviting others to join Clubhouse to form an even more robust community. We also rely on the interests of Non-Users in finding people they may know on Clubhouse upon joining, and gaining access to specific content on Clubhouse via invitations sent by Clubhouse users.

How long does Clubhouse retain Non-User information?

When we collect Non-Users’ phone numbers, we don’t store them. We process them for no more than a few seconds to create cryptographic hash values derived from the phone numbers. The cryptographic hash values are stored in a list on Clubhouse servers linked to the Clubhouse users who uploaded the phone numbers from which the hash values were derived.

If a user syncs her contacts, we keep this list of hash values for as long as the user instructs us to do so.

If a user invites you to join Clubhouse by entering your phone number manually but does not invite you to join a specific House, we keep the hash value derived from your phone number for no more than 14 days.

If a user invites you to join a specific House by entering your phone number manually, we keep the hash value derived from your phone number for no more than 180 days.

How do Non-Users exercise their data subject rights?

Data subjects have the right to access, rectify, and erase their information, as well as the right to restrict and object to certain processing of their personal information, in certain circumstances. You can learn more about those rights in our Privacy Policy. To exercise those rights, contact us via this form or via the address provided below. You also have the right to complain to a data protection authority in your country about our processing of your personal data.

Storage and transfer of Non-User Data

We are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We may also use service providers located outside of the EU or the UK. If we transfer your personal data out of the EU or the UK, we take measures to protect the confidentiality and security of your personal data, and your rights as a data subject.

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further information, you can review EU adequacy decisions here, and you can review UK adequacy decisions here.

If we transfer your personal data to a country that is not deemed to provide an adequate level of data protection, in order to protect your personal data we may use contractual clauses approved for use in the EU and/or UK in accordance with the EU and/or UK data protection regime(s).

Contact us

Alpha Exploration Co. (trading as Clubhouse) is responsible for Non-User data. This means we are the controller of Non-User data under the GDPR.

If you have questions about this Data Notice, you can contact us via this form, or by emailing privacy@clubhouse.com . You can also contact us at this mailing address:

Alpha Exploration Co. Inc.

548 Market Street PMB 72878

San Francisco, California 94104

USA

We have also appointed the following representatives:

• EEA and Switzerland: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23AT2P, Ireland; article27@verasafe.com.
• UK: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom; article27@verasafe.com.

If you are located in the EEA, Switzerland or the UK, you can contact the relevant representative about our processing of your personal data, in addition to or instead of contacting us.

Custom Voice Privacy Notice

Last Updated February 15, 2024

What are custom voices?

Clubhouse is a social network based on voice, but sometimes it’s easier to type than speak. A Clubhouse custom voice allows you to convert your text to spoken words to help you participate in audio conversations when you don’t want to (or can’t) speak aloud. You can use a pre-configured generic voice when you use the custom voice feature, or you can choose to create your own personal custom voice that will make your text replies sound like you are speaking (a “Custom Voice”). This notice explains how Clubhouse collects, uses, shares, retains, deletes, and otherwise handles (collectively, “processes”) your voice recordings choose to activate the Custom Voice feature.

By activating the Custom Voice feature and selecting “continue” where prompted, you consent to the practices described in this notice. If you change your mind later, you can delete your Custom Voice at any time in your account settings, and. we will apply your preferences going forward.

How does Clubhouse create my personal custom voice?

When you activate the Custom Voice feature, Clubhouse will request voice sample(s) to create your personal Custom Voice. We will analyze your voice recordings and create a unique text-to-speech model that you can use to convert written text into audio that mimics your voice. Clubhouse does not use your voice recordings or your Custom Voice to uniquely identify you. Nevertheless, depending on your location, applicable laws might define your Custom Voice as a biometric identifier, biometric information, or biometric data. Depending on your location, we rely on your consent as the legal basis to process your voice recordings for the purposes listed in this notice.

Who has access to my personal custom voice?

Clubhouse shares your voice recordings with a service provider (identified in our Data Processor List) who analyzes those recordings to create the text-to-speech model that powers your personal custom voice. Limited Clubhouse personnel may also access your voice recordings and personal custom voice as needed for product support, improvement, or compliance purposes.

How long is my personal custom voice retained?

Clubhouse retains your Custom Voice so long as you maintain an active account with us or until you delete your Custom Voice, unless we are required by law (such as a warrant or subpoena) to keep your personal custom voice for a longer period. If your Clubhouse account remains inactive for three consecutive years, we will automatically delete your Custom Voice. When your Custom Voice is deleted (either because you asked us to or you haven’t used your account in three years), it is permanently erased such that the date cannot be recovered or reconstructed.

Additional Privacy Disclosures and Your Rights

For more information about the identity and contact details of the controller, how and why we process your personal information, the legal bases for processing, the data recipients, your rights and choices concerning our data practices, and our cross-border data transfers, please review our Privacy Policy available at https://privacy.clubhouse.com/. Unless as otherwise amended by this notice, our Privacy Policy continues to apply to our processing of your personal information.