Privacy Policy

Last Updated: January 15, 2026

1. Information We Collect

1.1 Information You Provide Directly

When you sign up for our waitlist or request information, we collect:

• Contact Information: First name, last name, email address, phone number (optional)
• Investment Profile: Expected investment range, investor type (retail, accredited, institutional)
• Referral Source: How you heard about HotelierX
• Communications: Any messages, inquiries, or feedback you send us

1.2 Information Collected Automatically

When you visit our website, we automatically collect:

• Device & Browser Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages viewed, time spent, click patterns, referral URLs
• Cookies & Tracking: Session data, preferences, analytics (see Cookie Policy below)

1.3 Information from Third Parties

We may receive information from:

• Social Media: If you connect via LinkedIn, Instagram, or X (Twitter)
• Analytics Providers: Google Analytics, Formspree (form submissions)
• Future KYC/AML Providers: When offerings launch (Persona, DealMaker, Carta)

2. How We Use Your Information

We use your information to:

1. Process Waitlist Signups: Confirm your position and send updates about HotelierX launches
2. Communicate with You: Send educational content, market insights, property updates, and investor resources
3. Verify Identity (Future): Conduct KYC/AML checks when securities offerings go live
4. Improve Our Services: Analyze user behavior to optimize the website and investor experience
5. Comply with Laws: Meet SEC regulations, anti-fraud requirements, and legal obligations
6. Marketing & Advertising: Send targeted campaigns (you can opt out anytime)
7. Protect Our Platform: Prevent fraud, abuse, and unauthorized access

3. How We Share Your Information

We do not sell your personal information. We may share data with:

3.1 Service Providers

• Email Platforms: Mailchimp, ConvertKit (investor updates)
• Form Processors: Formspree (waitlist and pitch deck requests)
• Analytics: Google Analytics (anonymous usage data)
• Hosting: Cloud infrastructure providers

3.2 Compliance & Legal Partners (Future Offerings)

• KYC/AML Providers: Persona (identity verification)
• Broker-Dealers: DealMaker (securities transactions)
• Transfer Agents: Carta (cap table management)
• Regulators: SEC, FINRA, state securities regulators (as required by law)

3.3 Business Transfers

If HotelierX is acquired, merged, or undergoes restructuring, your information may be transferred to the new entity.

3.4 Legal Requirements

We may disclose information to:

• Comply with court orders, subpoenas, or legal processes
• Enforce our Terms of Service or protect our rights
• Prevent fraud, illegal activity, or harm to individuals

4. Data Security

We implement industry-standard security measures:

• Encryption: SSL/TLS encryption for all data transmission
• Access Controls: Restricted access to personal data on a need-to-know basis
• Secure Storage: Data stored on encrypted cloud servers with regular backups
• Monitoring: Continuous monitoring for unauthorized access or breaches

5. Data Retention

We retain your information:

• Waitlist Data: Until you request deletion or unsubscribe
• KYC/AML Records (Future): Minimum 5 years after last transaction (SEC requirement)
• Communications: As long as necessary for business or legal purposes
• Analytics: Aggregated, anonymized data retained indefinitely

6. Your Privacy Rights

Depending on your location, you may have the right to:

6.1 Access & Portability

• Request a copy of your personal data
• Receive data in a machine-readable format

6.2 Correction & Deletion

• Update inaccurate or incomplete information
• Request deletion of your data (subject to legal retention requirements)

6.3 Opt-Out & Consent Withdrawal

• Unsubscribe from marketing emails (click "unsubscribe" in any email)
• Withdraw consent for data processing (may limit service access)

6.4 Object & Restrict Processing

• Object to automated decision-making or profiling
• Request restricted processing in certain circumstances

To exercise your rights, email: privacy@hotelierx.com

7. Cookies & Tracking Technologies

We use cookies to:

• Essential Cookies: Enable core functionality (e.g., session management)
• Analytics Cookies: Track usage patterns (Google Analytics)
• Marketing Cookies: Deliver targeted ads and measure campaign performance

You can control cookies via:

• Browser settings (disable or delete cookies)
• Opt-out tools: Google Analytics Opt-Out

8. Third-Party Links

Our website may link to third-party sites (e.g., social media, partners). We are not responsible for their privacy practices. Review their policies before providing information.

9. Children's Privacy

HotelierX is not intended for individuals under 18. We do not knowingly collect data from minors. If you believe a child has provided information, contact us immediately at privacy@hotelierx.com.

10. International Users

HotelierX operates in the United States. If you access our site from outside the U.S.:

• Your data may be transferred to and processed in the U.S.
• U.S. privacy laws may differ from your country's regulations
• By using our site, you consent to this transfer

For EU/UK users: We comply with GDPR principles. Contact our Data Protection Officer at dpo@hotelierx.com.

11. California Privacy Rights (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to Know: Request details about data collected, used, and shared
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of data sales (we do not sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices

To submit a CCPA request, email privacy@hotelierx.com with "California Privacy Request" in the subject line.

12. Changes to This Privacy Policy

We may update this Privacy Policy as our business evolves or regulations change. Updates will be posted with a new "Last Updated" date. Continued use after changes constitutes acceptance.

13. Contact Us

For privacy questions, data requests, or concerns:

By using HotelierX's website and services, you acknowledge that you have read, understood, and agree to this Privacy Policy.