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THE EN PRIMEUR CLUB

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PRIVACY POLICY

Last updated: January 13, 2026

Pearl LLC ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and web services (collectively, the "Service").

1. Information We Collect

1.1 Personal Information You Provide

  • Account: email, password (encrypted), full name, username
  • Profile: profile photo, Instagram handle, homebase city
  • User-Generated Content: visit records, location ratings, notes, bookmarks, event attendance, AI assistant conversations
  • Communications: feedback, support requests

2. How We Use Your Information

  • Provide and Maintain the Service: account management, visits tracking, leaderboards, passport
  • Personalization: AI-powered recommendations
  • Analytics and Improvement: understand usage patterns
  • Communication: updates, support, policy changes
  • Achievements and Gamification: XP points, leaderboard rankings
  • Security: fraud detection, Terms of Service enforcement

2.1 Automated Decision-Making and Profiling

Our AI assistant uses automated processing for personalized recommendations. Users can opt-out by contacting us at concierge@enprimeurclub.com.

3. Data Storage and Security

  • Data Hosting: secure cloud database, servers in the United States
  • Encryption: TLS 1.2+ for data in transit; bcrypt for passwords
  • Access Controls: Row Level Security (RLS), principle of least privilege
  • Storage: secure storage buckets with encryption at rest

Data Retention

  • Active accounts: retained while active
  • Deleted accounts: deleted or anonymized within 30 days
  • Backup data: persists up to 90 days
  • Analytics data: aggregated and anonymized, retained indefinitely

4. Data Sharing and Disclosure

We do NOT sell personal information. We share data only: with your consent, with service providers (Supabase, PostHog, Azure OpenAI, Mapbox), or as public information (profile, leaderboard rankings, visit records).

5. Your Rights

  • Correction and Update: via the app Settings page
  • Deletion: contact concierge@enprimeurclub.com; deleted within 30 days

6. Children's Privacy

The Service is not intended for children under 13. We will delete information collected from children under 13 within 48 hours of becoming aware of such collection.

7. International Compliance

7.1 GDPR Compliance (European Users)

Our legal grounds for processing include: Consent, Contract Performance, Legitimate Interests, and Legal Obligations.

7.2 CCPA Compliance (California Users)

California residents have the Right to Know, Right to Delete, Right to Opt-Out, and Right to Non-Discrimination. Contact concierge@enprimeurclub.com for requests; we respond within 45 days.

8. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

9. Contact

Pearl LLC
2108 N ST STE N
Sacramento, CA 95816
Email: concierge@enprimeurclub.com