Elite Lake Rentals Privacy Policy

1. DEFINITIONS

For purposes of this Privacy Policy:

• “Personal Information” means any information that identifies, relates to, describes, or could reasonably be linked to an individual or household.
• “Processing” means any operation performed on Personal Information, including collection, use, storage, disclosure, or deletion.
• “Service Providers” means third parties that process Personal Information on our behalf.
• “Third Parties” means entities that are not Service Providers and may process Personal Information for their own purposes.
• “Identity Resolution Data” means data derived from combining identifiers, behavioral data, and third-party sources to associate individuals or devices with profiles.

2. SCOPE AND APPLICABILITY

This Privacy Policy applies to:

• Visitors to our website
• Guests and prospective guests
• Property owners and business partners
• Individuals interacting with our marketing, advertising, or communications

This Policy applies regardless of device or method of access.

3. CATEGORIES OF PERSONAL INFORMATION COLLECTED

We may collect the following categories of Personal Information:

A. Identifiers

• Name, email address, phone number
• Mailing and billing address
• IP address and device identifiers

B. Financial & Transactional Data

• Reservation details
• Payment transaction data (processed via third-party payment processors)
• Billing records

C. Internet & Network Activity

• Browsing behavior
• Pages visited, clicks, scroll depth
• Session duration
• Referral sources

D. Geolocation Data

• Approximate location derived from IP or device data

E. Commercial Information

• Booking history
• Service preferences
• Customer interactions

F. Communications Data

• Emails, SMS messages, call recordings
• Customer support interactions

G. Inferences & Profiles

• Preferences, interests, and behavioral characteristics inferred from activity

H. Third-Party Data

• Data obtained from partners, analytics providers, advertising networks, and identity resolution vendors

4. METHODS OF COLLECTION

We collect Personal Information through:

• Direct user submission
• Automated technologies (cookies, pixels, scripts)
• APIs and integrations with third-party systems
• Identity resolution and data enrichment services
• Offline interactions and communications

5. IDENTITY RESOLUTION, DATA ENRICHMENT, AND PROFILING

We utilize identity resolution and data enrichment technologies, which may include:

• IP address matching
• Device fingerprinting techniques
• Cross-device tracking
• Data obtained from third-party data brokers and partners
• Publicly available information

These technologies may:

• Associate anonymous website activity with identifiable individuals or households
• Generate probabilistic or deterministic matches
• Create or enhance profiles based on aggregated data

Important Disclosures:

• Such processes may involve inferred, modeled, or probabilistic data, which may not always be accurate.
• We make no representations or warranties regarding the accuracy, completeness, or reliability of such data.
• We do not use such data for decisions producing legal or similarly significant effects without human involvement.

6. PURPOSES OF PROCESSING

We process Personal Information for the following purposes:

A. Contractual Necessity

• Processing reservations and payments
• Providing customer support
• Managing bookings and guest services

B. Legitimate Business Interests

• Website analytics and performance optimization
• Fraud detection and prevention
• Internal business operations and administration
• Security monitoring and risk mitigation

C. Marketing, Advertising, and Retargeting

• Behavioral advertising
• Cross-platform tracking and attribution
• Audience segmentation and personalization

D. Legal and Compliance

• Compliance with applicable laws and regulations
• Enforcement of contractual rights
• Protection of our legal interests

7. LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)

Where required by applicable law, we rely on:

• Performance of a contract
• Legitimate interests
• Consent (where required)
• Compliance with legal obligations

8. DISCLOSURE OF PERSONAL INFORMATION

We may disclose Personal Information to:

A. Service Providers

Including but not limited to:

• Property management systems (e.g., Streamline VRS)
• Payment processors
• Cloud infrastructure providers
• Marketing automation and CRM platforms
• Analytics providers

These entities process data on our behalf under contractual obligations.

B. Advertising and Data Partners

We may share identifiers and behavioral data with third parties for:

• Cross-context behavioral advertising
• Retargeting
• Campaign attribution

Important: This may constitute “sharing” under certain laws (e.g., CPRA).

C. Property Owners and Operational Partners

To facilitate reservations, property access, and guest services.

D. Legal Authorities and Compliance

We may disclose information:

• To comply with legal obligations
• In response to subpoenas or lawful requests
• To protect rights, safety, and property

E. Corporate Transactions

In connection with mergers, acquisitions, financing, or asset sales.

9. COOKIES AND TRACKING TECHNOLOGIES

We use:

• First-party and third-party cookies
• Pixels and web beacons
• Tracking scripts and tags
• Local storage technologies

These technologies enable:

• Session management
• Analytics and performance monitoring
• Advertising and retargeting
• Identity resolution

Cookie Categories

• Essential
• Functional
• Analytics
• Advertising

User Controls

Users may:

• Modify browser settings
• Use industry opt-out tools
• Disable cookies (with potential impact on functionality)

10. SMS AND EMAIL COMMUNICATIONS COMPLIANCE

SMS (TCPA)

By providing a phone number, users consent to receive messages, including:

• Transactional messages
• Marketing messages (where permitted)

Users may:

• Opt out by replying STOP
• Request assistance by replying HELP

Email (CAN-SPAM)

We provide:

• Clear identification of sender
• Opt-out mechanisms
• Prompt processing of unsubscribe requests

11. DATA RETENTION

We retain Personal Information:

• For the duration of the customer relationship
• As required by applicable law
• As necessary for dispute resolution, enforcement, and risk management

We may retain anonymized or aggregated data indefinitely.

12. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards. However:

Important: We do not guarantee absolute security. Users acknowledge that transmission of data over the internet carries inherent risks.

13. USER RIGHTS AND REQUESTS

Subject to applicable law, individuals may have rights to:

• Access Personal Information
• Request correction
• Request deletion
• Opt out of targeted advertising
• Restrict or object to processing

Requests may be submitted to: legal@elitelakerentals.com

We reserve the right to verify identity before fulfilling requests.

14. CALIFORNIA PRIVACY RIGHTS (CPRA)

California residents may:

• Request disclosure of categories and sources of Personal Information
• Request deletion and correction
• Opt out of “sharing” for advertising
• Limit use of sensitive information

We do not sell Personal Information for monetary consideration.

15. DISCLAIMER OF THIRD-PARTY PRACTICES

We are not responsible for:

• Third-party privacy practices
• External platforms, booking systems, or payment providers
• Data processing performed outside our control

16. CHILDREN’S PRIVACY

We do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information from a child under 13 without verified parental consent, we will delete that information promptly. Parents or guardians who believe their child under 13 may have provided Personal Information should contact us at legal@elitelakerentals.com.

17. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time. Continued use constitutes acceptance of changes.

18. LIMITATION OF LIABILITY

To the fullest extent permitted by law:

• We disclaim liability for unauthorized access, data breaches, or third-party misuse of data.
• We are not responsible for indirect, incidental, or consequential damages arising from data processing activities.

19. CONTACT INFORMATION

Elite Lake Rentals LLC

legal@elitelakerentals.com