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Privacy Policy


Updated: 27 July, 2025


This Privacy Policy governs the practices of how Sable Club Holdings Limited (Company Registration Number: 2025-001664803) collects, uses, transfers, and shares personal information related to the use of our Services by our Users (referred to herein as “you”, “your”, or “yours”). This Policy is designed to ensure the transparent, lawful, equitable, and secure management of the personal data of our Users.

Our Privacy Policy explains what kind of personal data we gather through Services, which include services you access through Sable Club websites and any other sites associated with Sable Club (collectively referred to as “the Website”), Sable Club applications and software developed by Sable Club independently or through contractual third parties, including the self-custodial wallet, web applications, mobile applications, trading platforms, and any other applications and software associated with Sable Club (collectively referred to as “the Platform”) as well as all products, smart contracts and protocols. It demonstrates how and why we collect personal data, our purposes for its use, and the third parties with whom we may share it. Moreover, it explains how you as a data subject may exercise your rights in relation to your personal data.

Should any alterations be made to this Policy (alongside other policies, including our Terms of Service), we will notify you of such changes through our official communication channels, including email, and internal notifications, as well as directly on this page.

We strongly encourage you to read this Policy in its entirety to understand the processes involving your data and your associated rights. For inquiries related to this Privacy Policy, data collection and usage, data disclosure, and sharing, or any other concerns or requests related to your personal data, please do not hesitate to get in touch with us by writing to us at contact@sableclub.com.

1. INTERPRETATION AND DEFINITIONS

1.1. Interpretation

In this Policy, words with an initial capitalized letter are assigned specific meanings under the conditions described herein. These definitions shall retain their consistent meaning irrespective of their grammatical form (singular or plural).

1.2. Definitions

In these Terms, except where the context otherwise requires, the following words and expressions have the following meanings:

  • Policy refers to this Privacy Policy, including any updates or amendments that may be made;

  • Application means the software program provided by the Company, downloaded by you on any electronic device, named Sable Club;

  • Application Store means the digital distribution service operated and developed by Apple Inc. (Apple App Store) or Google Inc. (Google Play Store) from which the Application has been downloaded;

  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority;

  • Country refers to Wyoming, United States of America;

  • Company (referred to as either "the Company," "We," "us," or "our" in this Policy) refers to Sable Club Holdings Limited, located at 1908 Thomas Ave Ste 12018 Cheyenne, WY 82001 (the rule regarding initial capitalized letters does not apply to this term);

  • Parent Company refers to our Parent Company (of the same name as the Company), registered in the British Virgin Islands under Company Number 2175028;

  • Applicable Law refers to any law, rule, regulation, statute, ordinance, protocol, guideline, treaty, or judicial, administrative, or departmental directive, ruling, or order (whether in Hong Kong or another jurisdiction) intended to govern or regulate any party, property, transaction, or activity related to these Terms. This includes rules issued by any governmental or regulatory authority;

  • Account refers to the custodian Account established by the user through our Application in connection with these Services;

  • Cryptocurrency (including Crypto or digital asset) refers to blockchain-based digital assets, cryptocurrencies, or virtual currencies that uses encryption techniques to regulate the creation of non-fiat currency units and verify fund transfers, functioning independently of any central bank;

  • Wallet refers to a digital asset wallet used to store private keys, securely access digital assets, and allow the owner to send or receive digital assets;

  • Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet;

  • Service refers to the Application and all its related functions and content;

  • Third-party Social Media Service means any services or content (including, but not limited to, data, information, products, or services) provided by a third party that may be displayed, included, or made available by the Service;

  • Cookies refer to small files placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses;

  • Personal Data signifies any information that pertains to an identified or identifiable natural person;

  • Service Provider means any natural or legal person who processes data on behalf of the Company. This term encompasses third-party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on the Company's behalf, to perform services related to the Service, or to assist the Company in analyzing Service usage patterns;

  • Usage Data refers to data automatically collected, whether generated through the use of the Service itself or derived from the Service's underlying infrastructure (for example, the duration of a page visit);

  • You (also referred to as "your," "user," or "customer") refers to any individual or entity accessing or using these Services provided by the Company (the rule regarding initial capitalized letters does not apply to this term).

2. COLLECTION OF PERSONAL DATA

2.1. In order to provide our Services, we need to gather information about you. We strive to collect as little personal information from you as possible, minimizing it to the information strictly necessary to provide our Services. This information may be collected by various means, for example, directly from you when you reach out to us by email, or, in some cases, through third parties, to an extent necessary to provide our Services.

2.2. We will never request information related to your racial or ethnic background, personal life, sexual orientation, political views, philosophical or religious beliefs, biometric or genetic data, or trade union membership.

2.3. While you interact with our Service, We may request that you provide us with certain information, including but not limited to personal identification information, biometric, location, camera access, and other relevant information. This information can be employed to ensure you can fully access our services. Such information may include, but is not limited to:

A. PERSONAL IDENTIFICATION

We request access and save your email, first name and last name, phone number during the KYC (Know your Customer) process.

B. BIOMETIC

We request biometric-based authentication (e.g. facial or voice recognition/ fingerprint) for secure and convenient Account verification.

C. POST NOTIFICATIONS

We request access to notification permissions to keep you informed with essential updates, reminders, and important content. Allowing push notifications ensures that you stay up to date with the latest information about your Account.

D. LOCATION

We collect approximate location data from your device to enhance the security of your Account and minimize potential risks, validating your activity and safeguarding your information. When performing identity verification (Know your Customer), we may request access to your location information to verify the authenticity of the identity information you have submitted. This is done to comply with relevant laws, regulations, and risk control requirements. Such location information is used only temporarily during the verification process. We assure you that your location information will not be shared or sold to any third party unless required by law or regulatory obligations.

E. CAMERA

We request access to your device's camera to capture photos of your ID and facial images as part of the KYC verification process. This access is strictly limited to the verification process, and we do not access or store any other photos or videos on your device.

F. READ EXTERNAL STORAGE

We request access files stored on your device, such as retrieving the device ID, which is required to create a personalized user experience.

G. WRITE EXTERNAL STORAGE

We request access to store your device ID and settings on external storage to maintain your preferences and ensure the app operates smoothly.

Normal Permissions:

H. AD ID

We may use your Google Advertising ID (GAID) to analyze advertising data and deliver a more personalized and optimized advertising experience. This is required by services like AdMob.

I. INTERNET ACCESS

We request access to the internet to enable features like content updates and communication with backend services.

J. ACCESS NETWORK STATE

We request access to check your network information, including your network address, connection status, and connection type. This helps us optimize the app’s performance and ensure a seamless experience under varying conditions.

K. ACCESS WIFI STATE

We request access to check your device’s Wi-Fi connection status to enhance security and optimize content delivery. This permission is necessary for the functionality of certain third-party tools.

L. BIND GET INSTALL REFERER SERVICE

We request access to use Google Play Services to track app installations and measure the effectiveness of marketing campaigns.

M. WAKE LOCK

Our app remains functional and notifications are delivered even if your device is in sleep mode, avoiding interruptions.

N. NFC

We may utilize NFC (Near Field Communication) for any future enhancements related to secure payments or quick data transfers.

Other Data:

O. ACCOUNT DATA

Profile pictures and avatars, User-generated content (profile descriptions, bios), User preferences and settings

P. USAGE DATA

Website or Platform usage patterns, Session durations, Pages visited, Clickstream data, Error logs and crash reports

Q. REFERRAL DATA

Information about new Users referred to the Platform through referral programs and partnership mechanisms

R. COMMUNICATIONS DATA

Information submitted to you through our communication channels and over the course of our communication with you through the Customer Support channels, for example, via SMS or email; Survey responses; Information submitted through chatbots

2.4. All sensitive permissions are requested only with your explicit consent and are transparently outlined in the app’s Privacy Policy.

3. USAGE OF PERSONAL DATA

3.1. Our collection, use, and sharing of your personal data are founded on various lawful bases, depending on the context. The following scenarios represent the circumstances in which we engage in data collection:

3.2. We process your personal data when you grant your explicit consent. This typically occurs when you have reviewed our data processing purposes through our Terms of Use, Privacy Policy and other pages on our Platform, and willingly agreed to them by checking a box or clicking on a “I Agree” button. Other examples may include subscribing to our marketing notifications and campaigns or permitting the use of your personal information to enhance your experience while using our Services. You may explicitly opt out from receiving communications about our products, services, and events that are similar to those you have previously purchased or inquired about. Otherwise, we may send you such updates from time to time.

3.3. We process your information when it is essential to perform a contract with you (for example, our Terms of Service). This encompasses situations where your data is required for processing and finalizing your orders or adhering to the terms of any other contractual agreement we have entered into with you. It also includes enforcing the terms of this Policy and other agreements, providing our Services, ensuring the quality of our Services, and offering customer service and support.

3.4. We use your data when there is a legal obligation that necessitates data disclosure. This occurs when compliance with legal requirements imposed by law or legal orders is mandatory.

3.5. We may process your personal data when we have a legitimate interest that aligns with the operation and provision of our Services. This includes activities aimed at improving our Services, maintaining proper security measures, and preventing illegal activities related to your data. Our legitimate interests are pursued only when they do not infringe upon your fundamental rights.

A. Lawful Basis Clauses

  • in order to ensure your access to and use of our Services and the entire functionality of the Sable Club ecosystem. Category of Personal Information: Basic User Data, Account Data, Location Data

  • managing the operation and maintenance of our Services to ensure their functionality and availability. Category of Personal Information: Basic User Data, Account Data, Location Data, Wallet Data, Usage Data, Referral Data, Communications Data, Social Media Data, Marketing Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data

  • communicating with you for customer support, responding to your questions and inquiries via email and through social media channels. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Communications Data

  • providing information and notifications regarding changes and updates to the Services, and important service-related information. Category of Personal Information: Basic User Data, Usage Data, Communications Data, Social Media Data

  • sending various communications, including notifications, reminders, and confirmations, to keep you informed about your activities involving our Services. Category of Personal Information: Basic User Data, Usage Data, Communications Data, Social Media Data

  • promoting the safety, security, and integrity of our Services and data through protective measures and ongoing monitoring, including those aimed at preventing fraud and misuse of our Services. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Communications Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data

B. Legitimate Interest

  • continuously improving the quality, performance, and features of our Services to grow our business continuously, to implement the industry's best practices and adhere to its standards, to attract potential customers and users to use the Services. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Referral Data, Communications Data, Analytics Data, Research Data

  • conducting research and development activities related to our Services, including the development of new features, functionalities of the Application, and the introduction of new products and services; to improve the functionality of our Services, to ensure the competitiveness of our Services, to grow our business and attract potential customers and users by introducing novel features and ensuring continuous development of the Services. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Referral Data, Communications Data, Social Media Data, Marketing Data, Analytics Data, Activity Data

  • performing measurement and analytics to understand how our users interact with our Services, analyze user behavior, and identify user preferences, to learn how users interact with and use our Services, the Website and the Platform, to conduct studies, to develop marketing strategy and implement amendments to the Services, fixes, and new features. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Referral Data, Communications Data, Social Media Data, Analytics Data, Research Data

  • to ensure security of your data, to prevent unauthorized access to your Account and irreversible loss of funds. Category of Personal Information: Basic User Data, Account Data, Location Data, Blockchain Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data

  • tailoring user experiences based on preferences and behaviors for personalized content and recommendations, to ensure that our users receive information and content that they opt to see, to enhance user experience and customer satisfaction. Category of Personal Information: Basic User Data, Account Data, Location Data, Communications Data, Analytics Data, Research Data, Activity Data, Cookies Data

  • engaging third-party service providers for specific tasks such as research, marketing, analytics, Website and Platform management, development and operability, and customer support. Category of Personal Information: Basic User Data, Account Data, Location Data, Usage Data, Communications Data, Social Media Data, Marketing Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data

  • collecting user feedback to improve our services and gather valuable insights, to gather feedback from our users to learn of errors, issues and problems arising from the use of Services, to implement fixes, to develop new features and ensure the customer satisfaction with our Services. Category of Personal Information: Basic User Data, Account Data, Location Data, Communications Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data

  • sharing data with partners, collaborators, or affiliates for joint initiatives, promotions, or integrated services, to ensure certain functionality of our Website and Platform, to develop and grow our business. Category of Personal Information: Basic User Data, Communications Data, Social Media Data, Marketing Data, Blockchain Data, Analytics Data, Research Data

  • providing educational resources and materials to enhance user knowledge and promote secure service usage. Category of Personal Information: Basic User Data, Social Media Data, Research Data

C. Compliance with Our Legal Obligations

  • ensuring compliance with relevant laws and regulations, including anti-money laundering, terrorism financing, fraud prevention, and other financial crime regulations. Ensuring that we do not deal with funds resulting from proceeds of crime, such as money laundering or terrorist financing, and do not assist in or facilitate in any manner any financial crime and other criminal activities. Category of Personal Information: Basic User Data, Account Data, Location Data, Wallet Data, Usage Data, Referral Data, Communications Data, Social Media Data, Marketing Data, Blockchain Data, Analytics Data, Research Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data

  • maintaining records for auditing, accounting, and compliance purposes in accordance with applicable laws. Category of Personal Information: Basic User Data, Account Data, Location Data, Wallet Data, Usage Data, Referral Data, Communications Data, Social Media Data, Blockchain Data, Platform, Website, and Device Data, Activity Data, Troubleshooting Data, Cookies Data

D. Your Consent

  • using social media channels for the purposes of advertising, notification, and marketing. Category of Personal Information: Basic User Data, Account Data, Communications Data, Social Media Data, Marketing Data, Analytics Data, Cookies Data

4. SHARING OF PERSONAL DATA

4.1. We may share the information we collect with various third parties to support and enhance our business operations.

4.2. We collaborate with vendors and service providers who assist us in maintaining and optimizing our business operations, particularly in ensuring regulatory compliance. These service providers perform a range of essential functions that strengthen our platform’s integrity and security.

4.3. To ensure compliance with legal requirements under relevant law and to uphold the safety, transparency, and lawfulness of your activities, including the creation of your Account, we utilize third-party identity verification services. By using our verification partners' services, we cross-reference the personal information you provide, or that is provided by a third party, with the information available in our verification partners' databases and/or public records.

4.4. In our commitment to providing you with a seamless experience, we may share certain information with advertisers who play a role in enhancing our Services. These advertisers assist us in delivering relevant content and promotions tailored to your interests. The information shared with advertisers may include user preferences, interaction patterns, engagement with advertising campaigns, and interest-based data. Our collaboration with advertisers aims to provide you with advertisements that align with your preferences and interests.

4.5. To jointly deliver integrated services, promotions, or joint initiatives, we may share specific information with our trusted business partners in various fields. The data shared with business partners can encompass a variety of relevant information to support our shared objectives. Any information shared is handled in compliance with data protection laws and regulations, and it is used exclusively for the purposes of delivering the intended services and enhancing your overall experience.

4.6. In exceptional circumstances and as required by applicable laws and regulations, we may share your information with law enforcement agencies and competent authorities. This is done to support investigations, maintain legal compliance, and ensure the safety and security of our Services and Users. It may be necessary in the case of court proceedings, complying with a legal order or other legal process, as well as for the purposes of financial crime, money laundering and terrorism financing prevention, if we have strong grounds to believe any natural or legal person to be involved in or associated with the said forms of crime.

4.7. In cases of our insolvency, bankruptcy, acquisition, transfer of ownership, sale of assets or succession, your personal information may be disclosed to the new owner, acquirer or successor of the company or other relevant third parties.

5. RETENTION OF PERSONAL DATA

5.1. Your personal information is held and stored securely for the duration of your active account with us. We are committed to retaining your personal information only for the period necessary to fulfil the specific purposes for which it was collected. The retention periods may vary depending on the type of personal information and the purposes for which it was initially gathered but will not be processed for more than 10 years after the original purpose of collection has been achieved, unless there are specific requirements stipulating otherwise for certain data. After this period, your personal data will only be retained if it has been anonymized.

5.2. If you request to delete your account and there is no history of participation in our Services, we will promptly remove your email address from our records. However, if your account contains history, we may retain your email address for archive purposes and to comply with applicable laws and regulations, including anti-money laundering policies.

6. TRANSFER OF PERSONAL DATA

6.1. Your information, including Personal Data, is meticulously processed at the Company's operational offices and at any other locations where the parties involved in the processing are situated. This implies that this information may be transferred to — and maintained on — computer systems located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those prevailing in your jurisdiction.

6.2. Your affirmative consent to this Policy, followed by your submission of such information, unequivocally signifies your agreement to such transfer.

6.3. The Company will undertake all steps reasonably necessary to ensure that your data is treated with the utmost security and in strict accordance with this Policy. No transfer of your Personal Data will occur to an organization or a country unless adequate controls are in place, explicitly encompassing the security of your data and other personal information.

7. DELETION OF PERSONAL DATA

7.1. You retain the right to delete, or request our assistance in deleting, the Personal Data that we have collected concerning you.

7.2. Our Service may provide you with the functionality to delete certain information about yourself from within the Service interface.

7.3. You may update, amend, or delete your information at any time by signing in to your Account, if applicable, and navigating to the Account settings section that facilitates the management of your personal information. Alternatively, you may contact us directly to request access to, correction of, or deletion of any personal information you have provided to us.

7.4. Please be advised, however, that we may be required to retain certain information when a legal obligation or a legitimate lawful basis necessitates such retention.

8. SECURITY

8.1. We consider the security of your personal information to be of paramount importance. We employ a range of technical, organizational, and administrative measures designed to safeguard your data against unauthorized access, disclosure, alteration, and destruction. These security measures include:

  • data encryption, for which we use industry-standard encryption protocols to protect data during transmission and storage. This ensures that your information remains confidential and secure;

  • access controls, or making sure that your personal information is restricted to authorized personnel, partners and employees who require access for specific purposes. When these purposes are fulfilled, and the person no longer needs your data to perform their responsibilities, we may revoke access to your personal information to avoid its use for illegitimate purposes or purposes not related to the provision of services to you. Access controls and authentication mechanisms are implemented to verify and restrict access;

  • employee training, which ensures that our staff is trained in matters related to data security and that they handle your information with care and adhere to the terms of this Privacy Policy and all the relevant data protection laws and regulations;

  • data backups, which we perform to prevent data loss in case of unexpected events or system failures. In addition to that, we have established incident response procedures and regular security assessment to promptly address and mitigate any security incidents or breaches, should they occur;

  • the nature of blockchain technology itself, which inherently provides transparency, immutability, and decentralization.In other words, your transactional and personal data is stored securely across multiple nodes, reducing the risk of unauthorized alterations or data breaches;

  • granting you control over your data, meaning that as a User, you maintain control over your personal information through your Account and additional security settings available to you through the interface;

  • conducting regular audits and updates to identify and mitigate potential vulnerabilities or weaknesses in the Website’s and the Platform's infrastructure;

  • data minimization, which means that we collect and store only the minimum amount of personal information necessary to facilitate your transactions and provide our Services. Unnecessary data is not retained, reducing the potential impact of any security incidents;

  • user education, meaning that we actively provide resources and guidance to educate you about the nature of our Services and blockchain technology in general, blockchain security best practices, and the responsible management of private keys and cryptocurrency assets. In the long term, this self-awareness helps you understand and protect your data;

  • data storage, obtained through verification processes such as KYC or KYB, are kept by our third-party service provider, ensuring confidentiality, integrity and security of stored personal data;

  • third-party service provider security standards, which we require all registered partners to uphold. These third parties must implement robust data protection policies to prevent unauthorized access, use, or disclosure of your information;

  • multi-level security systems, which refers to our implementation of security measures across various layers of our infrastructure. This approach reduces the risk of data loss, misuse, or alteration by combining both physical and digital safeguards;

  • one-Time Password verification, which is an added layer of account security available to you to help prevent unauthorized access to your Account and personal information;

  • regular internal security reviews, where we assess our data collection, storage, and processing practices, including physical security protocols, to detect and prevent vulnerabilities and unauthorized access;

  • confidentiality enforcement, under which all authorized personnel, contractors, and agents with access to your personal data are bound by strict confidentiality agreements and may be subject to disciplinary actions, including termination, for any breach;

  • regulatory compliance, which we strictly observe to ensure your information is handled in accordance with applicable laws and standards related to data protection;

  • Privacy Policy governance, meaning that we review our Privacy Policy regularly to ensure it remains aligned with best practices and evolving legal requirements;

  • complaints and regulatory cooperation, meaning that if you raise a formal written complaint, we will reach out to you promptly. Where a concern remains unresolved, we work with the appropriate regulatory authorities to address the matter efficiently and transparently;

8.2. If you ever have concerns about the security of your data, suspect any unauthorized activity, or would like to know the specific measures undertaken to secure your personal data, please don't hesitate to contact us via email at contact@sableclub.com.

8.3. In the event of a data breach, we will promptly notify you and advise you to change your passwords to help prevent any potential future breaches.

9. COOKIE POLICY

9.1. We use Cookies on our website to gather information about our users’ interaction with our Services. Information we collect via Cookies may include your use of the Website and Platform features, the frequency of your visits, your interaction with the functionalities of the Services, and other relevant information. We use Cookies to ensure the secure operation of our Services, enhance your experience, and support the delivery of all web-based features. Cookies help us understand how our Services are used, remember your preferences, and tailor our platform to better suit your needs.

9.2. Cookies are small pieces of text sent by your web browser when you visit our Website. Cookies may store user preferences and other information. Cookies provide a convenience feature to save you time or tell the Web server that you have returned to a specific page. A Cookie file is stored in your web browser and allows the Service or a third party to recognize you and make your next visit easier and the Service more useful to you. For instance, upon visiting the Platform, Google Stats will track the Platform’s performance and assess online advertising effectiveness, but only when you access the Website.

9.3. Cookies can be “persistent”, “session”, “first-party” or “third-party” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while session Cookies are deleted as soon as you close your web browser.

9.4. In addition to persistent and session Cookies, Cookies can be categorized into first-party and third-party. Cookies set directly by us are called “first-party Cookies”. Cookies set by parties other than the website owner are called “third-party Cookies”. Third-party Cookies enable third-party features or functionality to be provided on or through the website.

9.5. When accessing the Website, you will be asked to confirm your choice regarding Cookie preferences, such as what Cookie categories you wish to accept and which Cookies you want to decline, or a choice to decline all Cookies altogether. If you choose to accept all or some of these Cookies, please note that the following information contained in this Section relates to Cookies used on our Website and the Platform only and does not apply to any other pages and websites that may be hyperlinked to our Website. To read more about the categories of Cookies used on our Website, please refer to the next subsection. For more general information about Cookies and their use, you may visit http://www.allaboutCookies.org/.

9.6. We may use the following types and categories of Cookies on the Website:

  • essential Cookies, which are strictly necessary for the proper functioning of the Website and provide basic functionalities such as page navigation and access to secure areas of the website;

  • functional Cookies, which are used to enhance website functionality and provide personalized features. For example, these Cookies may remember user preferences and settings;

  • performance Cookies, which are used to collect information about the Website’s performance, for example, how visitors use the website, which pages they visit most often and if they encounter any error messages;

  • targeting or marketing Cookies, which are used to deliver advertisements and marketing campaigns to you and deliver more personalized service. The Cookies may be set by us directly as well as by our third-party partners that help us carry out marketing campaigns and allow us to deliver personalized and more tailored marketing information to you. If you opt-in to use these Cookies, information you provide to us regarding your marketing preferences will be collected by us and added to your marketing profile to deliver more targeted advertisements and provide content that is relevant to you. In addition, we will use this information to measure the effectiveness of our advertising and marketing campaigns;

  • analytics Cookies, which are used to gather information about the Website usage and traffic patterns. This data is aggregated and anonymous, helping us understand how visitors interact with the Website and the Platform, gather statistical information, and use it to improve the quality and relevancy of our services.

9.7. You have a right to change the categories of Cookies you consented to, opting out, withdrawing your consent from the choice made earlier, or refusing to accept Cookies altogether even if you consented to some or all of them in the past. You can follow the instructions provided by Your browser or Device (usually located under “Settings” or “Preferences”) to modify Your Cookie or pixel data settings. Please note that disabling Cookies may affect the functionality of certain parts of Our Services.

9.8. Alternatively, you may choose to block all Cookies by accessing the relevant feature in the browser you use to access the Website. Blocking Cookies can be done in various ways, depending on the browser and device you're using: to learn about how you can block Cookies through the browser of your choice, please visit the settings page of your browser or the dedicated help page.

9.9. Please note that if you choose to block all Cookies or opt out of their use altogether, some of the functionalities of our Website may become unavailable to you, and we will not be able to provide you with the full range of features and services.

10. COMPLAINTS HANDLING

10.1. We are committed to addressing any concerns about data protection:

  • if we receive a formal written complaint, our team will promptly reach out to the individual who raised the issue;

  • for unresolved concerns, we collaborate with the relevant regulatory authorities to ensure compliance and resolve the matter efficiently.

10.2. To ensure the security of your Account and transactions, we may perform necessary assessments of your device status, such as checking whether the device is rooted or if developer debugging mode is enabled. This information is used solely for local security evaluation or risk control purposes and will not be stored, shared, or used for any other purpose. When using the WebView component within the application, it is only used to open official webpages, such as help documents. We commit to not using Cookies or fingerprint tracking through WebView to safeguard your privacy.

10.3. By combining advanced technology, stringent policies, and regulatory cooperation, we strive to provide a secure and trustworthy platform for managing your personal data.

11. CHILDREN’S PRIVACY

11.1. Our Service is not directed to, nor does it knowingly collect information from, anyone under the age of 18. We do not knowingly collect personally identifiable information from individuals under the age of 18. If you are a parent or guardian and you become aware that your child has provided Us with Personal Data, please contact us immediately. Should we discover that we have collected Personal Data from anyone under the age of 18 without verifiable parental consent, we will promptly take steps to remove that information from our servers.

11.2. Furthermore, if we are required to rely on parental consent as a legal basis for processing your information, and your country's regulations mandate consent from a parent, we may necessitate your parent's explicit consent before we proceed with the collection and use of that information.

12. LINKS TO EXTERNAL WEBSITES

12.1. Our Service may incorporate links to external websites that are not operated by us. If you click on a third-party link, you will be redirected to that third party's website. We strongly advise you to diligently review the Privacy Policy of every website you visit.

12.2. We exert no control over, and consequently assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

13. DISCLAIMER

13.1. After using Third-Party services, you acknowledge that this Policy no longer applies to their collection, use, disclosure and transfer of your personal information. We cannot guarantee that any third parties will implement reasonable security measures to protect your personal information.

13.2. You are solely responsible for using Third-Party services and agree that you will not hold us liable for any losses or damages incurred from such third parties’ collection, use, disclosure and transfer of your personal information by these third parties.

13.3. You acknowledge and accept that, to the maximum extent permitted by Applicable Law, we will take all reasonably available measures to protect your personal information on an “as is”, “as available” and “with all faults” basis, in accordance with existing technology, to minimize disclosure, alteration, or damage. Due to data transmission over wireless networks, we cannot guarantee the privacy or security of wireless Internet data transmission.

14. TRANSLATION AND AMENDMENT

14.1. These Terms and Conditions may have been translated if we have made them available to you on our Service. You agree that the original English text shall prevail in the case of a dispute.

14.2. The Company reserves the right to unilaterally amend this Policy at any time at its sole discretion. Amendments will become effective upon publication on the Company’s website. You are responsible for keeping yourself informed of the latest version. Your continued use of the Services constitutes your acceptance of any amended terms. If you do not agree to the amendments, you must immediately cease using the Services.

15. COMMUNICATION

15.1. To assist you in addressing questions or issues related to your use of our Services, we provide the following customer support resources designed to ensure a responsive user experience.

  • A comprehensive FAQ page that covers a wide range of common queries and concerns. The FAQ page serves as the initial point of reference for addressing common account-related inquiries which you may utilize before raising your concerns directly with the dedicated Support Team.

  • For more personalized and Account-specific inquiries, or other questions not explicitly covered by our Information Page or our community pages, we maintain a dedicated Support Team. You may reach out to our Support Team by sending an email to contact@sableclub.com.

16. CONTACT

Company name:

Sable Club Holdings Limited

Email Address:

contact@sableclub.com

Address:

1908 Thomas Ave Ste 12018 Cheyenne, WY 82001

Working Hours:

Monday to Friday 9am to 6pm

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