Privacy Policy

01Scope & Definitions

This Privacy Policy describes how MVCC (Club LVL) — also branded as "Club Level" and "LVL:MVCC," and referred to herein as "we," "us," or "our" — collects, uses, discloses, and protects personal information through the LVL Privé membership program, the signup page located at this domain, related digital properties, and on-premises operations at 8 Hampshire Street, Lawrence, Massachusetts.

"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you. "You" refers to any prospective, current, or former Privé member or visitor.

By submitting the signup form, presenting identification at the host stand, or entering the premises, you acknowledge that you have read and understood this Privacy Policy.

02Information We Collect

Information you provide directly

• Membership signup data: first name, last name, email address, and a photograph or scan of a government-issued identification document (driver's license, state identification card, or passport).
• Acknowledgments: your attestation that you are twenty-one (21) years of age or older, and your acceptance of our Terms & Conditions and Membership Agreement.
• Optional communications: any messages or inquiries you send to us via email, telephone, or social media.

Information collected automatically

• Technical data: IP address, browser type and version, device identifiers, operating system, referring URLs, pages visited, and timestamps. This information is collected by our hosting provider (Netlify) and used for security, fraud prevention, and aggregate analytics.
• Form metadata: submission identifiers and form-name tags used to route and store your submission.

Information collected on premises

• Visual surveillance: the premises are monitored by closed-circuit video for security, safety, and incident investigation purposes. Areas under surveillance are signed at points of entry.
• Membership scan logs: when you scan in at the host stand, we record the date, time, and identity of the staff member who verified you.

03How We Use Information

We use the information collected to:

• Verify your age and identity in accordance with the Massachusetts private club exemption framework and applicable alcohol-service regulations.
• Establish, administer, and maintain your LVL Privé membership, including the issuance and reissuance of a physical membership card.
• Maintain a record of bona fide member enrollment as required to preserve our status as a private membership association.
• Communicate with you regarding membership status, premises operations, events, security incidents, and policy updates.
• Detect, investigate, and prevent fraud, unauthorized access, identity misrepresentation, underage entry attempts, and other security or safety incidents.
• Comply with legal obligations, respond to lawful requests from public authorities, and assert or defend legal claims.
• Improve our digital signup experience and our on-premises member services.

We do not use your personal information for purposes that are materially different from those described above without providing notice or, where required, obtaining consent.

04Government ID Photos

Photographs and scans of your government-issued identification are treated as sensitive personal information and are handled with elevated controls. Specifically:

• ID images are transmitted to our hosting provider over an encrypted connection (TLS) and stored within secured infrastructure.
• Access to stored ID images is limited to authorized MVCC (Club LVL) personnel performing membership verification or responding to a documented security or legal matter.
• ID images are not used for any purpose other than identity and age verification, fraud prevention, and legal compliance.
• ID images are not sold, rented, traded, or disclosed to third-party marketers under any circumstance.
• After your identity has been verified at the host stand and your Privé card has been issued, the stored ID image is retained only for the period described in Section 7 ("Data Retention").

05Sharing & Disclosure

We do not sell or rent your personal information. We share information only as follows:

• Service providers: our website, signup form, file storage, database, and email infrastructure are operated by trusted providers, including Netlify, Inc. and its underlying hosting partners. These providers process information on our behalf under contractual confidentiality and security obligations and are not permitted to use it for their own purposes.
• Legal compliance: we may disclose information when required to do so by law, subpoena, court order, regulatory authority, or other valid legal process, or when we believe in good faith that disclosure is necessary to protect our rights, safety, or property, or that of our members or the public.
• Safety and incident response: in the event of a security incident, threat of harm, or emergency, we may share relevant information with law enforcement, emergency responders, or other affected parties.
• Business transfers: if MVCC (Club LVL) is involved in a merger, acquisition, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to the protections of this Policy.

06Storage & Security

Personal information is stored in databases and file-storage systems operated by Netlify, Inc., with physical infrastructure located in the United States. We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include encryption in transit, restricted database access via service-role credentials, application-level access controls, audit logging, and periodic review of staff access permissions.

Despite our efforts, no method of transmission over the internet or method of electronic storage is one-hundred-percent secure. We cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately using the contact information in Section 14.

07Data Retention

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Specific retention windows include:

• Membership record: retained for the duration of your active membership and for up to seven (7) years thereafter to satisfy regulatory, tax, and dispute-resolution requirements.
• Government ID image: retained for up to ninety (90) days after your identity has been verified at the host stand, after which the image is permanently deleted unless retention is required by an active investigation, legal hold, or open dispute.
• Surveillance video: retained for up to thirty (30) days unless flagged for an active investigation or legal matter.
• Technical and log data: retained for up to twelve (12) months for security and operational purposes.

You may request earlier deletion of your information as described in Section 8. We may decline a deletion request to the extent retention is required for the reasons set forth above.

08Your Rights & Choices

Subject to applicable law and reasonable identity verification, you may exercise the following choices with respect to your personal information:

• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate or incomplete information.
• Deletion: request that we delete your personal information, subject to retention obligations described in Section 7.
• Membership termination: request that your Privé membership be terminated. Termination does not automatically erase records we are required to retain.
• Marketing opt-out: opt out of marketing communications by replying "unsubscribe" to any marketing email or by contacting us directly.

To exercise any of these rights, contact us using the information in Section 14. We will respond within a reasonable time and in accordance with applicable law. We will not discriminate against you for exercising any of these rights.

09Cookies & Tracking

Our signup site uses a minimal number of cookies and similar technologies, limited to those that are strictly necessary for the operation of the form (including spam prevention) and for security purposes. We do not use third-party advertising or behavioral retargeting cookies on the signup site.

Most browsers allow you to refuse or delete cookies through browser settings. Disabling strictly necessary cookies may impair the functionality of the signup form.

10On-Premises Recording

MVCC (Club LVL) is a private membership venue. Audio, video, and still-photography recording may take place on the premises for security, safety, marketing, and editorial purposes. By entering the premises you consent to being recorded and to the use of those recordings as described in our Terms & Conditions and Membership Agreement.

11California Residents

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), provides additional rights. Specifically, you have the right to know what personal information we collect about you, the right to request deletion, the right to correct inaccurate information, the right to opt out of the sale or sharing of personal information (we do not sell or share personal information as those terms are defined under California law), and the right to non-discrimination for exercising these rights.

To exercise California rights, contact us as described in Section 14. We will verify your identity using the information you provided during signup before responding to your request.

12Minors

MVCC (Club LVL) is a strictly twenty-one-and-over venue. We do not knowingly collect personal information from any individual under the age of twenty-one. If we become aware that we have collected information from a person under twenty-one, we will delete that information promptly. Membership is void in any case where the applicant was not, in fact, twenty-one years of age or older at the time of application.

13Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. When we do, we will revise the "Last updated" date at the top of this page. For material changes, we will provide additional notice, which may include a notice on this site or a direct communication to active members.

Your continued use of the LVL Privé membership program after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms.

14Contact

Questions, comments, or requests regarding this Privacy Policy may be directed to:

MVCC (Club LVL) — LVL:MVCC
Attention: Privacy
8 Hampshire Street
Lawrence, MA 01840
privacy@clublvllawrence.com