Club 500 by JMB Privacy Policy

1. Who we are

Club 500 by JMB is a private automotive lifestyle members club based in Dubai, United Arab Emirates. The club is operated by Club 500 by JMB Inc., a C corporation incorporated in the State of Delaware, United States ("Club 500", "we", "us"). We operate in the United States and the United Arab Emirates. In the UAE, we operate through JMB Management Ltd., based in Dubai.

This policy explains how we collect, use, share and protect personal data when you visit c500.ai, apply for membership, become a member, attend our events or contact us. We are the controller of your personal data and we process it in line with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) in the UAE, and with applicable US federal and state privacy laws in the United States.

For any privacy question, contact our Data Protection Officer at support@c500.ai.

2. Information we collect

We collect only what we need to run the club and look after our members.

• Identity and contact details: full name, date of birth, nationality, email, phone number, postal address and photograph.
• Identity documents: passport, Emirates ID or other government ID, and driving licence for driving experiences.
• Membership information: application answers, referral source, membership tier, preferences, interests and event attendance.
• Background screening results: the outcome of sanctions, politically exposed person (PEP) and adverse media checks, and any police clearance certificate you choose to provide.
• Payment information: billing details and payment records. Card payments are processed by our payment provider and we do not store full card numbers.
• Communications: messages exchanged with your dedicated attaché by email, phone or WhatsApp, and feedback you send us.
• Event and venue information: attendance records, and photographs or video taken at club events.
• Website data: IP address, device and browser type, pages visited and cookie data.

We collect this information from you directly, from the identity verification and screening providers named in section 3, from members who refer you, and from our venue and experience partners when you use their services through the club.

3. Membership vetting and identity verification

Club 500 is invite only. To protect our members, partners and reputation, we verify the identity of every applicant and screen them before membership is approved.

• Identity verification: you upload a photo of your identity document and take a short selfie. Our verification provider, Sumsub, checks that the document is genuine and that it belongs to you. This involves processing your facial image to compare it with your document photo.
• Screening: we check your name, date of birth and nationality against international sanctions lists, PEP lists, law enforcement watchlists and public news sources for adverse media.
• Ongoing monitoring: while you are a member, we may re-screen you periodically so we are aware of material changes.
• Police clearance: we may ask you to provide a police clearance or good conduct certificate.

Screening results are reviewed by an authorised member of our team. A potential match is never treated as a final decision on its own, and you may ask us to review any outcome. We ask for your consent to these checks in the membership application, and an application cannot proceed without it.

4. How we use your information

We do not sell your personal data. We do not use screening results for any purpose other than membership decisions and keeping the club safe.

We use technology, including our Identic AI platform, to help your attaché plan connections and experiences. Decisions about your membership are always made by people, not by automated systems alone.

5. Who we share it with

We share personal data only where needed, and only with parties bound to protect it.

• Identity verification and screening providers, such as Sumsub, which verify documents and run sanctions, PEP and adverse media checks on our behalf.
• Experience and venue partners, such as vehicle providers and partner venues, limited to what they need to deliver a booking you have made, for example your name and driving licence for a drive.
• Service providers for payments, hosting, email, communications and event management.
• Professional advisers, including lawyers, auditors and insurers.
• Authorities, where the law requires it or to protect the safety of our members, staff or the public.

We do not share screening results with other members or with partners.

6. International transfers

Some of our providers store or process data outside the UAE. When this happens, we make sure the transfer is permitted under the PDPL and that appropriate safeguards, such as contractual data protection terms, are in place.

7. How long we keep it

We keep member data for as long as you are a member, then for 7 years to meet legal, tax and accounting requirements in the UAE and the United States. If an application is declined or withdrawn, we keep identity and screening records for 12 months, unless the law requires longer. Identity document images and selfies are held by our verification provider under the same limits.

8. How we protect it

We use access controls, encryption in transit and at rest through our providers, and staff confidentiality obligations. Only authorised team members can see identity documents and screening results.

9. Your rights

You have the right to:

• know what personal data we hold about you and receive a copy
• ask us to correct inaccurate data
• ask us to delete your data, where we are not required to keep it
• restrict or object to certain processing
• withdraw your consent at any time, without affecting earlier processing
• ask for a human review of a decision based on screening results
• complain to the UAE Data Office

To use any of these rights, email support@c500.ai. We reply within 30 days.

US residents. Depending on the state you live in, you may have additional rights, including the right to know what categories of personal information we collect and why, and the right to opt out of the sale of personal information or its use for targeted advertising. We do not sell personal information and we do not share it for targeted advertising. We will not treat you differently for exercising your privacy rights. You may use an authorised agent to make a request, and we will verify your identity before acting on it.

Age. Membership is open only to adults aged 21 and over. We do not knowingly collect personal data from anyone under 18.

10. Cookies

Our website uses essential cookies to work properly and, with your consent, analytics cookies to understand how it is used. You can change your choice at any time through the cookie banner or your browser settings.

11. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. We will tell members directly about any significant change.

12. Contact us

Club 500 by JMB Inc. (a Delaware corporation) Operating in the United States and the United Arab Emirates. UAE operations through JMB Management Ltd., Dubai. Email: support@c500.ai Phone: +971 58 109 4167