Privacy Policy

Last updated: November 5th, 2019

When you use Smart Member™, you are trusting us with your personal information, and we do our best to manage that information with the upmost integrity and security, to ensure we have happy users.

I. Personally-Identifiable Information and Non-Personally Identifiable Information.

Smart Member, LLC (also referred to herein as “Smart Member™”) may collect two different types of information, Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”). PII that we collect is information that identifies you as an individual – and includes your name, address, telephone number, e-mail address, credit card information, billing address and shipping information. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and other information that does not reveal your specific identity. PII and Non-PII may be collected anytime you access or use a Smart Member™ website. PII and Non-PII may also be collected by Smart Member™ during in-person discussions, telephone conversations, and electronic or other written communications. Smart Member™ also collects information via cookies; blocking cookies may render you unable to access certain Smart Member™ products, services, or websites.

Smart Member™ uses PII to respond to your inquiries, provide you with services you have requested, keep you informed of services Smart Member™ thinks may be of interest to you, and otherwise personalize your experience with Smart Member™, and other reasons. Smart Member™ does not sell or lease PII about you to others, and may in some cases be liable for so doing under the Privacy Shield Framework outlined below. Smart Member™ will provide your e-mail address to affiliates or users who refer you to us, or through whom you create a Smart Member™ account. Smart Member™ shares your PII with Smart Member™ affiliates and third parties contracting with Smart Member™ to provide services to you, including financial institutions, API integrators you have chosen, and other third party software services that you have chosen to assist you with your membership sites. Smart Member™ employees who design our databases and software, and those employees who provide you with customer service, along with our customer service software partners, also have access to PII as part of their job in providing services to You. Smart Member™ may also share PII when required by law, or when you have expressly requested Smart Member™ to do so. Smart Member™ reserves the right to disclose and use your PII if Smart Member™ believes it is necessary to: (a) respond to legal process, e.g., a subpoena; (b) respond to a law enforcement agency’s request; (c) enforce the Terms; or (d) protect the rights, privacy, safety, property, or operations of Smart Member™ or third parties; (e) improve the products and services offered.

Because Non-PII does not personally identify You, Smart Member™ reserves the right to use and disclose to third parties Non-PII for any purpose.

Smart Member™ maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Smart Member™ enforces its Privacy Policy via self-assessment.

Smart Member™ reserves the right to change this privacy notice, which changes will become effective upon posting of the revised notice on, or upon emailing of the changes to You at the email address You provided to Smart Member™, or as required by law.

II. Links to or From Other Sites.

Except where expressly stated by Smart Member™, Smart Member™ is not affiliated or associated with operators of any third party websites that link to or are linked from any Smart Member™ maintained website. Smart Member™ disclaims any responsibility for the accuracy or content of information found on third party websites that link to or are linked from any Smart Member™ website. Smart Member™ disclaims any responsibility for the security of any information (including without limitation credit card and personally identifiable information (“PII”)) that you may provide to any third party. Smart Member™ reserves the right, at any time and in its sole and absolute discretion, to block links to any Smart Member™ maintained website through technological or other means without prior notice.

III. Information; Registration; User Names and Passwords

As a Smart Member™ website user, you will be required to create an account with Smart Member™. You warrant that the information you provide Smart Member™ is truthful and accurate, and that you are not impersonating another person. You are responsible for maintaining the confidentiality of any password you may use to access your Smart Member™ account, and you agree not to transfer your password or User name, or lend or otherwise transfer your use of or access to your account, to any third party. You are fully responsible for all transactions with, and information conveyed to, Smart Member™ under your account. You agree to immediately notify Smart Member™ of any unauthorized use of your password or User name or any other breach of security related to your account. You agree that Smart Member™ is not liable, and you will hold Smart Member™ harmless, for any loss or damage arising from your failure to comply with any of the foregoing obligations.

IV. EU-US and Swiss-US Privacy Shield Frameworks.

Smart Member™ complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. Smart Member™ has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit For full definitions of the Privacy Shield Principles, please visit

Under the Privacy Shield, you have the right to access, correct, or delete your personal data. You also have the right to limit Smart Member™ use of your data – including the right to opt-in or out of receiving communications from Smart Member™. To exercise any of these rights, please send an email to

Third party data transfer. Smart Member™ may be liable for the transfer of EU and/or Swiss personal data to third parties acting as our agents unless we can prove we are not responsible for the event given rise to the damages.

The Choice Principle. Note that we may be required to release personal data of EU and/or Swiss individuals in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Smart Member™ commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should contact Smart Member™ at:


Regular Mail:

Smart Member
Attn: Legal Department
3722 S. Las Vegas Blvd, Suite 2509
Las Vegas, NV 89158
United States

Smart Member™ has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

Under certain limited conditions, individuals in the European Union or Switzerland may have the right to invoke “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

The Federal Trade Commission has jurisdiction with enforcement authority over Smart Member™’ compliance with the Privacy Shield.

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