Privacy Policy

1. Information We Collect

The information we collect depends on how you use the Platform.

Information You Provide Directly

We may collect information you provide to us, including:

• name;
• email address;
• phone number;
• city and state;
• account login information;
• display name;
• profile photograph;
• biography or headline;
• professional or business interests;
• Regional Leader selection;
• secondary community or region selection;
• website and social media links;
• contact-sharing preferences;
• meetup RSVPs;
• attendance or check-in information;
• feedback and survey responses;
• Regional Leader applications;
• community forum posts, comments, replies, reactions, and uploaded photos;
• networking and connection requests;
• testimonials, member spotlights, stories, photographs, or other content you choose to submit;
• support requests and Platform feedback; and
• other information you voluntarily provide through the Platform.

You are not required to provide information that is not necessary for the feature you choose to use, although certain Platform features may not work without required information.

Account and Profile Information

Members who create a Directory Login may create a member profile.

Depending on the information you choose to provide and your Platform settings, profile information may include your display name, profile photo, city and state, Regional Leader affiliation, biography, headline, business or professional interests, social media accounts, and website.

Certain profile information is designed to be visible to other members of the community.

The Platform is designed so that phone numbers and email addresses are shared through member-facing networking features only where the member has opted into contact sharing.

Meetup and RSVP Information

When you RSVP for a meetup, we may collect information such as your name, email address, meetup selection, and related attendance information.

If you attend a meetup, we may also record:

• QR-code check-ins;
• manually recorded attendance;
• self-reported attendance;
• the meetup you attended;
• Regional Leader or region associated with the event; and
• attendance history.

The Platform uses this information for event administration, follow-up communications, badges, networking features, and reporting.

Community Content

If you participate in community chats or forums, we collect the content and activity associated with your participation, including:

• posts;
• replies;
• photographs;
• reactions;
• channel and region information;
• timestamps; and
• moderation information.

Community communications are not private communications with NRE 2.

Authorized team members may access community content for moderation, safety, support, quality assurance, enforcement of Community Guidelines or Terms, investigation of reports, and improvement of the Platform.

The Platform provides administrators with moderation access to messages across regions, including the ability to search, hide, review, and delete content.

Please do not post sensitive, confidential, or highly personal information in community areas.

Networking Information

If you use My Network or other connection features, we may collect information regarding:

• member connection requests;
• accepted connections;
• QR-code connections;
• which meetup a connection originated from;
• networking activity; and
• networking milestones.

Contact information is displayed through relevant networking features only where the applicable member has opted into sharing it.

Feedback and Survey Information

When you submit Platform feedback or a post-meetup survey, we may collect your responses along with information that helps us understand the context of the feedback, such as the relevant meetup, Regional Leader, page, account, or technical issue.

The Platform’s current workflow allows feedback and survey information to be viewed in the administrative panel and synced into internal reporting systems.

Photographs and Recordings

Creative Community Meetups may be photographed, filmed, livestreamed, or otherwise recorded.

If you attend a meetup, your image, likeness, voice, or appearance may be captured in event photography or recordings.

Recordings submitted through the Platform may be reviewed by authorized administrators before being released to members.

Additional terms concerning photography and recordings are contained in our Terms of Use.

2. Information Collected Automatically

When you use the Platform, we or service providers acting on our behalf may automatically collect certain technical and usage information, which may include:

• Internet Protocol address;
• browser type;
• device type;
• operating system;
• referring or exit pages;
• date and time of access;
• pages viewed;
• links or buttons clicked;
• session or login activity;
• approximate geographic information derived from technical information;
• error or diagnostic information; and
• similar usage information.

We may use cookies, local storage, pixels, or similar technologies to operate the Platform, maintain sessions, remember preferences, understand usage, improve performance, and maintain security.

3. How We Use Information

We may use information we collect to:

• operate and maintain the Platform;
• create and manage member accounts;
• authenticate users;
• provide member profiles and directory functionality;
• administer Regional Leader communities;
• manage meetup RSVPs and attendance;
• send meetup confirmations and reminders;
• communicate schedule, location, or cancellation changes;
• provide community forums and networking features;
• maintain connection and attendance histories;
• provide badges and milestones;
• provide approved meetup replays;
• respond to questions, requests, and support needs;
• moderate community content;
• investigate reports, misconduct, abuse, or suspected violations;
• protect the security and integrity of the Platform;
• administer Regional Leader applications;
• collect and analyze member feedback;
• understand Platform usage and community engagement;
• generate internal reports and analytics;
• troubleshoot technical issues;
• improve existing features and develop new ones;
• communicate with members regarding the Platform and community;
• comply with applicable law;
• enforce our Terms of Use and Community Guidelines; and
• protect the rights, safety, and property of NRE 2, our members, Regional Leaders, and others.

The Platform currently uses member and activity information in internal reporting regarding areas such as attendance, community engagement, networking, profile completion, Regional Leader activity, and geographic coverage.

4. How We Disclose Information

We do not disclose personal information indiscriminately.

We may disclose information in the following circumstances.

Regional Leaders

Regional Leaders may receive information reasonably necessary to administer their communities and meetups.

Depending on the feature, this may include:

• member names;
• regional member rosters;
• RSVP information;
• attendance or check-in information;
• attendee lists;
• profile information;
• community posts; and
• information necessary to communicate with meetup participants.

Regional Leader dashboards are designed to provide access to regional rosters, RSVPs, check-ins, attendee exports, and community activity.

Regional Leaders are expected to use this information for legitimate community and event-administration purposes.

Other Members

Information you choose to include in member-facing portions of the Platform may be visible to other authorized members.

This may include your:

• display name;
• profile photograph;
• city and state;
• Regional Leader affiliation;
• headline;
• biography;
• professional interests;
• website or social media information;
• community posts; and
• other information you choose to make available through community features.

Your contact information may be available through certain networking features when you have opted into sharing it.

Service Providers

We may disclose information to vendors, contractors, and service providers that help us operate the Platform.

These may include providers assisting with:

• website hosting;
• databases;
• authentication;
• email delivery;
• cloud storage;
• analytics;
• customer support;
• security;
• file storage;
• spreadsheets or reporting tools;
• technical infrastructure; and
• similar business operations.

These providers may process information on our behalf as necessary to provide their services.

Legal, Safety, and Compliance Purposes

We may disclose information if we reasonably believe disclosure is necessary to:

• comply with applicable law, legal process, subpoena, or government request;
• enforce our agreements and policies;
• investigate suspected fraud, abuse, or unlawful activity;
• protect the rights or safety of NRE 2, members, Regional Leaders, or others;
• respond to an emergency; or
• establish, exercise, or defend legal claims.

Business Transactions

If NRE 2 is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction, information may be disclosed or transferred as part of that transaction, subject to applicable law.

5. Sale or Sharing of Personal Information

NRE 2 does not intend to sell personal information in exchange for money.

California law may define “sale” or “sharing” more broadly than an ordinary monetary sale, particularly where personal information is disclosed for cross-context behavioral advertising.

We will maintain our practices and disclosures regarding sale or sharing of personal information in accordance with applicable law.

If the Platform engages in activity that qualifies as a “sale” or “sharing” of personal information under applicable California law, we will provide any legally required opt-out mechanism, including recognition of applicable opt-out preference signals such as Global Privacy Control where required.

California requires qualifying businesses that sell or share personal information to provide an opt-out process, and applicable businesses must honor Global Privacy Control signals.

6. Cookies and Tracking Technologies

We may use cookies and similar technologies to:

• keep users logged in;
• remember preferences;
• maintain Platform security;
• understand how the Platform is used;
• diagnose technical issues; and
• improve Platform functionality.

Some third-party service providers may also collect information through technologies integrated with the Platform.

Do Not Track

Some browsers offer a “Do Not Track” (“DNT”) setting.

There is not a universally accepted technical standard for responding to traditional DNT signals. Accordingly, the Platform may not respond to conventional browser DNT settings unless required by applicable law.

Where legally required, however, we will recognize applicable legally binding opt-out preference signals, including Global Privacy Control.

California’s online privacy law specifically requires operators to disclose how they respond to Do Not Track mechanisms and whether third parties may collect information about users’ activities across websites.

7. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide the Platform;
• maintain account and attendance histories;
• administer meetups and community activities;
• maintain security;
• resolve disputes;
• investigate misconduct;
• comply with legal obligations;
• enforce agreements; and
• maintain appropriate business records.

Different categories of information may be retained for different periods.

For example, content hidden by a moderator may remain available to authorized administrators even when it is no longer visible to members, while administrators may permanently delete content where retention is not appropriate.

We may also retain information in backups or archives for a reasonable period after it is removed from active systems.

Where applicable law requires specific retention limitations, we will comply with those requirements.

8. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However, no website, database, electronic communication, or Internet transmission is completely secure.

We therefore cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your login credentials and should notify us if you believe your account has been compromised.

9. Your Choices and Controls

Depending on how you use the Platform, you may be able to:

• update your member profile;
• change certain profile information;
• control whether certain contact information is shared;
• change your Regional Leader or region settings where available;
• manage networking participation;
• choose what information you post in community forums;
• unsubscribe from certain non-essential communications; and
• request access to, correction of, or deletion of certain personal information.

Some transactional communications, such as account notices, security messages, RSVP confirmations, event reminders, or event changes, may be necessary to provide services you requested.

10. California Privacy Rights

This section applies to California residents.

California law provides various privacy protections. The specific rights available to you may depend on which California law applies to NRE 2 and to the particular information involved.

California Online Privacy Protection Act

California’s Online Privacy Protection Act (“CalOPPA”) requires operators of commercial websites and online services that collect personally identifiable information from California consumers to conspicuously post a privacy policy containing specified disclosures.

California residents may contact us using the information below to request review or correction of personal information associated with them where such functionality is not already available through their account.

CCPA and CPRA Rights

To the extent that NRE 2 is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), California residents may have the following rights:

Right to Know. You may have the right to request information concerning the categories and specific pieces of personal information we have collected about you, the sources of that information, our purposes for collecting it, and categories of third parties to whom it has been disclosed.

Right to Delete. You may have the right to request deletion of personal information we collected from you, subject to legal exceptions.

Right to Correct. You may have the right to request correction of inaccurate personal information.

Right to Opt Out of Sale or Sharing. If we sell or share personal information as those terms are defined by California law, you may have the right to direct us not to do so.

Right to Limit Use of Sensitive Personal Information. Where applicable, you may have the right to limit certain uses or disclosures of sensitive personal information.

Right to Non-Discrimination. We will not unlawfully discriminate against you for exercising applicable California privacy rights.

California’s Attorney General identifies these as key rights provided under the CCPA.

Categories of Personal Information

Depending on your interaction with the Platform, we may collect categories of personal information recognized under California law including:

Identifiers, such as name, email address, phone number, online identifiers, IP address, and account information.

Customer-record information, such as contact information you provide.

Commercial or participation information, such as meetups you RSVP for or attend and your participation in Platform programs or activities.

Internet or electronic activity information, such as Platform usage, browsing activity, interactions, device information, and technical logs.

Geolocation information, such as city and state you provide or approximate location derived from technical data.

Audio, electronic, visual, or similar information, such as photographs, videos, uploaded images, and meetup recordings.

Professional or employment-related information, when you voluntarily include business or professional information in your profile, application, biography, or community submissions.

Inferences, such as information derived from Platform activity for purposes of understanding member engagement, preferences, or community participation.

We collect these categories from you directly, from your interactions with the Platform, from Regional Leaders administering community activities, and from service providers supporting Platform operations.

We use them for the business and operational purposes described in this Privacy Policy.

Submitting a California Privacy Request

To submit a privacy request, contact:

NRE 2, LLC

Email: support@subto.com

You may also submit a request through any privacy-request form we make available through the Platform.

We may need to verify your identity before completing certain requests.

Where permitted by law, an authorized agent may submit a request on your behalf. We may request information reasonably necessary to verify the agent’s authority and your identity.

We will respond within the time period required by applicable law.

The California Attorney General notes that qualifying CCPA businesses generally must respond to requests to know or delete within 45 days, subject to permitted extensions.

11. Sensitive Information

The Platform is not intended to collect highly sensitive personal information through community forums or ordinary member profiles.

Please do not post or upload information such as:

• Social Security numbers;
• government identification numbers;
• financial account credentials;
• payment card credentials;
• passwords;
• private financial records;
• medical records;
• confidential legal documents; or
• similar highly sensitive information

into community chats, member profiles, or other areas visible to members or Regional Leaders.

The community moderation notice specifically advises members not to share sensitive or confidential information in community conversations.

If sensitive information is posted inappropriately, we may remove or restrict it.

12. Children and Minors

The Platform is intended only for individuals who are 18 years of age or older.

We do not knowingly permit individuals under 18 to create accounts, RSVP through the Platform, or participate in Creative Community Meetups.

If we learn that information has been collected from an individual under 18 in violation of this policy, we may take reasonable steps to remove the information and terminate the associated account or participation.

If you believe a minor has provided personal information through the Platform, please contact us.

13. Third-Party Websites and Services

The Platform may contain links to or integrate with third-party websites or services.

Those third parties have their own privacy practices, and this Privacy Policy does not govern their independent collection or use of information.

We encourage you to review the privacy policies of third-party services before providing them with personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to:

• the Platform;
• our information practices;
• technology;
• legal requirements; or
• business operations.

When we make material changes, we may notify users through the Platform, by email, or by another reasonable method.

The “Last Updated” date at the top of this Privacy Policy identifies when it was most recently revised.

California guidance recommends keeping privacy policies current and updating them as practices change.

15. Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, or have concerns regarding our privacy practices, contact:

NRE 2, LLC

Privacy Contact: support@subto.com

For meetup-specific questions, you may also contact your Regional Leader.

For general Platform feedback, you may use the Feedback feature available on the Platform.