TG HOSPITALITY LLC - PRIVACY POLICY

TG Hospitality LLC ("TG Hospitality," "Company," "we," "us," or "our") is a limited liability company organized under the laws of the State of New Mexico, United States. We are committed to protecting the privacy and personal data of our clients and website visitors worldwide.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at www.tghospitality.com (the "Site") or engage our luxury hospitality management and concierge services (the "Services"). This Policy applies to all users globally, including residents of the European Economic Area ("EEA"), United Kingdom ("UK"), California, and other jurisdictions with specific privacy legislation.

By accessing the Site or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Site or Services.

1. Information We Collect
1.1 Information You Provide Directly
We collect personal information that you voluntarily provide to us, including but not limited to:
•       Full name, title, and contact information (email address, phone number, mailing address)
•       Travel preferences, dietary requirements, accessibility needs, and lifestyle preferences
•       Passport details, visa information, and travel document data (when necessary to arrange travel services)
•       Payment and billing information (credit card details, billing address, invoicing data)
•       Corporate affiliation and role (for B2B and white-label partners)
•       Communications and correspondence with our team
•       Emergency contact details
•       Special requests and preferences related to hospitality services (accommodation, dining, entertainment, wellness, transportation)

1.2 Information Collected Automatically
When you visit our Site, we may automatically collect certain technical information, including:
•       IP address and approximate geolocation
•       Browser type, version, and language preferences
•       Device type, operating system, and screen resolution
•       Pages visited, time spent on pages, and navigation patterns
•       Referring URL and search terms used to find our Site
•       Cookies and similar tracking technologies (see Section 8)

1.3 Information from Third Parties
We may receive personal information about you from third-party sources, including our service partners (hotels, airlines, restaurants, event venues), referral partners, white-label clients, and publicly available sources. We combine this information with data we already hold to provide you with a more personalized service experience.

2. How We Use Your Information
We use the information we collect for the following purposes:
•       Service Delivery: To arrange and manage travel, accommodation, dining, entertainment, event planning, and other hospitality services on your behalf.
•       Communication: To respond to inquiries, provide service updates, and maintain our client relationship.
•       Personalization: To tailor our recommendations and services to your preferences and past experiences.
•       Payment Processing: To process transactions, send invoices, and manage billing.
•       Legal Compliance: To comply with applicable laws, regulations, and legal obligations.
•       Security: To protect against fraudulent, unauthorized, or illegal activity.
•       Business Operations: To manage our internal operations, including quality assurance, training, and service improvement.
•       Marketing: With your consent where required, to send promotional materials about our services and exclusive offers. You may opt out at any time.
•       B2B Partner Management: To manage white-label partnerships, process partner requests, and coordinate service delivery.

3. Legal Bases for Processing (EEA/UK Users)
If you are located in the European Economic Area or the United Kingdom, we process your personal data on the following legal bases under the General Data Protection Regulation ("GDPR") and the UK GDPR:
•       Contract Performance (Article 6(1)(b)): Processing necessary to perform our contractual obligations to you, including arranging travel, accommodation, and hospitality services.
•       Legitimate Interests (Article 6(1)(f)): Processing necessary for our legitimate business interests, such as improving our services, fraud prevention, and direct marketing to existing clients, provided these interests are not overridden by your rights.
•       Consent (Article 6(1)(a)): Where we rely on your consent, such as for marketing communications or the use of non-essential cookies. You may withdraw consent at any time.
•       Legal Obligation (Article 6(1)(c)): Processing necessary to comply with legal requirements applicable to us.

4. Sharing and Disclosure of Information
We may share your personal information with the following categories of recipients, solely to the extent necessary to deliver our Services or comply with legal obligations:
•       Service Providers and Partners: Hotels, airlines, restaurants, yacht charters, event venues, transportation companies, wellness providers, and other hospitality vendors necessary to fulfill your service requests.
•       White-Label Partners: If you access our Services through a white-label or B2B partner, we may share relevant service information with that partner as necessary.
•       Professional Advisors: Attorneys, accountants, auditors, and insurers providing professional services to us.
•       Payment Processors: Third-party payment processing companies that handle financial transactions on our behalf.
•       Legal and Regulatory Authorities: When required by law, court order, subpoena, or government request, or to protect our legal rights.
•       Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5. International Data Transfers
TG Hospitality operates globally, and your personal information may be transferred to and processed in countries outside your country of residence, including the United States and other countries where our service partners operate.For transfers of personal data from the EEA or UK to countries not deemed to provide an adequate level of data protection, we implement appropriate safeguards, including:
•       Standard Contractual Clauses (SCCs) approved by the European Commission.
•       The UK International Data Transfer Addendum, where applicable.
•       Other legally recognized transfer mechanisms as appropriate.

By using our Services, you acknowledge and consent to the transfer and processing of your personal information in countries that may have different data protection laws than your country of residence. We take all reasonable steps to ensure your data is treated securely and in accordance with this Privacy Policy.

6. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.
Specific retention periods include:
•       Client account and service records: Duration of the client relationship plus seven (7) years thereafter.
•       Financial and transaction records: Seven (7) years, in accordance with applicable tax and accounting regulations.
•       Marketing communications data: Until you withdraw consent or opt out.
•       Website analytics data: Twenty-six (26) months from collection.
•       Inquiry and correspondence records: Three (3) years from the date of the last communication.Upon expiration of the applicable retention period, personal data will be securely deleted or anonymized.7. Your Privacy Rights7.1 Rights for All UsersRegardless of your location, you may:•       Request access to the personal information we hold about you.
•       Request correction of inaccurate or incomplete information.
•       Opt out of marketing communications at any time by following the unsubscribe link in any email or contacting us directly.

7.2 Additional Rights for EEA/UK Residents (GDPR)If you are located in the EEA or UK, you have the following additional rights under the GDPR:
•       Right to Erasure: Request deletion of your personal data, subject to legal retention obligations.
•       Right to Restrict Processing: Request that we limit the processing of your data in certain circumstances.
•       Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format.
•       Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
•       Right to Withdraw Consent: Where processing is based on consent, withdraw at any time without affecting the lawfulness of prior processing.
•       Right to Lodge a Complaint: File a complaint with your local Data Protection Authority.

A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

7.3 Additional Rights for California Residents (CCPA/CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"):
•       Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes of collection, and the categories of third parties with whom we share your data.
•       Right to Delete: Request deletion of your personal information, subject to certain exceptions.
•       Right to Correct: Request correction of inaccurate personal information.
•       Right to Opt Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising. If this changes, we will provide a clear opt-out mechanism.
•       Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise any of these rights, please contact us using the information provided in Section 14. We will respond to verified requests within the timeframes required by applicable law (generally 30 days for GDPR, 45 days for CCPA).

7.4 Rights Under Other JurisdictionsIf you reside in other jurisdictions with applicable data protection laws (such as Canada's PIPEDA, Brazil's LGPD, Australia's Privacy Act, UAE's PDPL, or similar legislation), you may have additional rights. We will honor applicable rights in accordance with the relevant local law. Please contact us to exercise your rights.

8. Cookies and Tracking TechnologiesOur Site uses cookies and similar technologies to enhance your browsing experience, analyze site traffic, and understand user behavior. The types of cookies we use include:
•       Strictly Necessary Cookies: Required for the Site to function properly. These cannot be disabled.
•       Analytics Cookies: Help us understand how visitors interact with our Site (e.g., Google Analytics). These collect anonymized data.
•       Functional Cookies: Remember your preferences and settings to provide a personalized experience.
•       Marketing Cookies: Used to deliver relevant advertisements and measure campaign effectiveness.

These are only placed with your consent where required by law.

You can manage your cookie preferences through your browser settings or through our cookie consent banner when you first visit the Site.

For EEA/UK visitors, non-essential cookies will only be placed with your prior consent. Disabling certain cookies may affect the functionality of our Site.

We may also use web beacons, pixel tags, and similar technologies in our emails to track open rates and engagement.

9. Data Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
•       Encryption of data in transit (TLS/SSL) and at rest.
•       Access controls limiting data access to authorized personnel on a need-to-know basis.
•       Regular security assessments and vulnerability monitoring.
•       Secure storage of physical documents in controlled-access environments.
•       Confidentiality agreements with all employees and service providers who handle personal data.

While we strive to protect your personal information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to promptly addressing any breach in accordance with applicable notification laws.

10. Children's Privacy
Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

If we become aware that we have collected personal data from a child without verification of parental consent, we will take steps to delete that information promptly.

11. Third-Party Links
Our Site may contain links to third-party websites, services, or applications that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party site you visit. The inclusion of a link on our Site does not imply endorsement of the linked site.

12. Do Not Track Signals
Some browsers offer a "Do Not Track" ("DNT") feature. There is currently no uniform standard for how companies should respond to DNT signals. At this time, our Site does not respond to DNT signals. However, you may manage your cookie preferences as described in Section 8.13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will notify you by posting the updated policy on this page with a revised "Last Updated" date. For significant changes, we may also provide additional notice, such as an email notification. Your continued use of the Site or Services after any changes indicates your acceptance of the updated Privacy Policy.

14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: TG Hospitality LLC
Email: contact@tghospitality.com
Website: www.tghospitality.com

For GDPR-related inquiries, you may also contact our designated privacy point of contact at the email address above. We will endeavor to respond to all legitimate requests within thirty (30) days.