Privacy Policy

Last updated 26 September 2022

This Privacy and Cookie Policy (the "Policy") becomes effective on June 26, 2022 for all users.

What Does This Policy Cover?

This policy describes how ASG II Hospitality Holdings, LLC, trading as Actabl and its wholly-owned subsidiaries Actabl Services, LLC, ProfitSword, LLC (“ProfitSword”), FivePals, Inc. and FivePals UK Ltd. (collectively, “Alice”), Transcendent Solutions, LLC (“Transcendent”), and Hotel Effectiveness Solutions, LLC (“Hotel Effectiveness”) (collectively referred to as "Actabl", "we" or "us" in this policy) will make use of your data when you use the website http://actabl.com/ (“Website”), contact us via phone or email, request to receive marketing from us or access our services online (“Services”).  

It also describes your data protection rights, including a right to object to some of the processing which Actabl carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What Information Do We Collect

We collect and process personal data about you when you interact with us and our Website, and when you use our Services. This includes:

What Information Do We Receive From Third Parties?

Sometimes, we receive information about you from third parties. We may also obtain information about you from other third-party services and organisations to enhance your experience.

How Do We Use This Information, and What Is the Legal Basis For This Use?

We process this personal data for the following purposes:

Withdrawing Consent or Otherwise Objecting to Direct Marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  

You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Who Will We Share This Data With, Where and When?

We will share your personal data with our subsidiaries Actabl Services, LLC, ProfitSword, Alice, Hotel Effectiveness and Transcendent for their internal business purposes or to provide you with a product or service that you have requested. 

Personal data will also be shared with third party service providers, who will process it on behalf of Actabl for the purposes identified above.  For example, IT services, payment processing services, to market products or services or deliver ads to you, analyse activity on the Services, provide content, and help to maintain our user database and administer emails, surveys, or other communications. 

For more detailed information on how we use these third-party services, please see below:

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

In the event that the business is sold or integrated with another business, we may share personal data in connection with an actual or proposed change in control, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.  Your details will be disclosed to our advisers and any prospective or actual purchaser’s adviser and will be passed to the new or prospective owners of the business.

Where information is transferred outside the UK or EEA, such as the United States, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or under the United Kingdom adequacy regulations, data is adequately protected by EU Commission or UK Information Commissioner approved standard contractual clauses or a vendor's Processor Binding Corporate Rules.  A copy of the relevant mechanism can be provided for your review on request to privacy@actabl.com.

If you access third-party services, such as Facebook, Google, or Twitter, through the services to login to the services or to share information about your experience on the services with others, these third-party services may be able to collect information about you, including information about your activity on our websites or through the services, and they may notify your connections on the third-party services about your use of the services, in accordance with their own privacy policies.

Information About Our Use Of Cookies 

What Are Cookies?

A cookie is a very small text document, which often includes a pseudonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about the use of cookies on www.allaboutcookies.org.

We also use other forms of technology which serve a similar purpose to cookies and which allow us to monitor and improve our website. When we talk about cookies, this term includes these similar technologies. 

What Cookies Do We Use And What Information Do They Collect?

Third Parties

Your use of the website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting includes content displayed from a third party website. You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country. A list of the third parties who place cookies on our website are:

How Do You Manage These Technologies?

If you want to delete any cookies that are already on your device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

To manage your cookie consent preferences, please click <a href="javascript: CookieConsent.renew()">here</a>.

We keep information collected from cookies for a maximum of 12 months.

What Rights Do I Have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). 

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. 

To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU or UK data protection authority where you live, work or where you believe a breach may have occurred. 

How Do I Get In Touch With You?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at privacy@actabl.com or by writing to 333 Douglas Road, E., Oldsmar, Florida 34677. 

How Long Will You Retain My Data?

We retain the Personal Data we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Contact Us

The data controller for your personal data will be Actabl.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at privacy@actabl.com

Updates To This Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.