PRIVACY POLICY

Effective Date: May 9, 2026
Last Updated: May 9, 2026

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1. Introduction

Welcome to Empire Luxe Living LLC (“Company,” “Empire Luxe Living,” “we,” “our,” or “us”). We are committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us through our website, services, communications, and property management operations.

This Privacy Policy explains how we collect, use, disclose, store, protect, and otherwise process personal information in connection with our residential and corporate housing management services, real estate operations, marketing activities, vendor relationships, owner partnerships, guest accommodations, and website interactions.

By accessing or using our website, submitting information to us, communicating with us, or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope of This Privacy Policy

This Privacy Policy applies to:

• Visitors to our website

• Property owners and prospective property owners

• Tenants, occupants, and guests

• Corporate housing clients

• Vendors, contractors, and service providers

• Prospective employees or independent contractors

• Individuals who communicate with us via email, forms, social media, phone, or messaging platforms

• Users interacting with our digital platforms, advertisements, or automated systems

This Privacy Policy does not apply to:

• Third-party websites linked from our website

• Third-party booking platforms

• Independent payment processors

• External property listing services

• Platforms not controlled by Empire Luxe Living

3. Information We Collect

A. Personal Information You Provide

We may collect personal information that you voluntarily provide, including but not limited to:

• Full name

• Mailing address

• Email address

• Telephone number

• Business information

• Property ownership details

• Lease or rental information

• Emergency contact information

• Government-issued identification information

• Financial and billing information

• Tax-related information

• Employment or income verification information

• Insurance information

• Booking or reservation information

• Communications and correspondence

• Uploaded documents or forms

• Service inquiries and consultation requests

B. Property and Transaction Information

In connection with property management and corporate housing services, we may collect:

• Property addresses

• Unit information

• Occupancy records

• Lease agreements

• Maintenance records

• Inspection reports

• Security deposit information

• Utility account details

• Vendor invoices

• Payment history

• Reservation histories

• Incident reports

• Guest stay information

• Access logs

C. Automatically Collected Information

When you visit our website or use our systems, we may automatically collect:

• IP address

• Browser type

• Device identifiers

• Operating system

• Website usage data

• Session activity

• Geolocation data

• Referral URLs

• Clickstream data

• Access timestamps

• Cookie identifiers

• Network and security logs

D. Sensitive Information

We do not intentionally collect sensitive personal information unless reasonably necessary for legitimate business, legal, contractual, or security purposes.

Where applicable, sensitive information may include:

• Identity verification documentation

• Background screening information

• Financial account details

• Payment authentication data

• Information required for legal compliance

Such information is handled with heightened safeguards and restricted access controls.

4. How We Use Information

We may use collected information for lawful business purposes, including:

Operational Purposes

• Managing residential and corporate housing properties

• Facilitating bookings and reservations

• Processing rental applications

• Coordinating maintenance and repairs

• Managing tenant and guest communications

• Processing payments and invoices

• Managing vendor relationships

• Conducting property inspections

• Providing customer support

Business and Administrative Purposes

• Operating and improving our website

• Managing owner accounts

• Analyzing operational performance

• Maintaining records

• Enforcing agreements

• Auditing and compliance activities

• Business continuity planning

• Fraud prevention and risk mitigation

Marketing and Communications

• Sending service-related notices

• Delivering newsletters and promotional communications

• Responding to inquiries

• Conducting surveys and market research

• Personalizing website experiences

• Advertising and retargeting campaigns

You may opt out of marketing communications at any time.

Legal and Security Purposes

• Detecting fraud or unlawful activity

• Preventing unauthorized access

• Protecting our systems and properties

• Verifying identity

• Enforcing our rights and agreements

• Complying with legal obligations

• Cooperating with law enforcement requests

• Protecting the safety of guests, tenants, owners, staff, and the public

5. Legal Bases for Processing

Where applicable under relevant privacy laws, we process personal information based on:

• Performance of contractual obligations

• Compliance with legal obligations

• Legitimate business interests

• Consent

• Fraud prevention and security interests

• Protection of vital interests

6. Cookies and Tracking Technologies

Our website may use cookies, pixels, SDKs, analytics tools, and similar technologies to:

• Maintain website functionality

• Improve user experience

• Analyze traffic and engagement

• Personalize content

• Detect security incidents

• Support marketing and advertising activities

Cookies may include:

• Essential cookies

• Analytics cookies

• Advertising cookies

• Functional cookies

• Session cookies

• Security cookies

You may adjust browser settings to refuse cookies; however, portions of the website may not function properly.

7. Analytics, Advertising, and Third-Party Technologies

We may use third-party providers for:

• Website analytics

• Advertising performance tracking

• CRM systems

• Email marketing

• Payment processing

• Booking and reservation systems

• Cloud hosting

• Cybersecurity monitoring

• Customer communications

• Property management software

These providers may collect information in accordance with their own privacy policies.

We may use technologies such as:

• Google Analytics

• Meta Pixel

• Advertising retargeting systems

• Session replay tools

• Fraud detection systems

• Cloud-based monitoring tools

We do not control third-party privacy practices.

8. Data Sharing and Disclosure

We may disclose information to:

Service Providers

Including:

• Payment processors

• Maintenance vendors

• Property management software providers

• IT and cybersecurity providers

• Cloud hosting services

• Marketing agencies

• Booking platforms

• Accountants and legal advisors

• Insurance providers

Property Owners and Partners

Where necessary to facilitate property management operations, bookings, maintenance, financial reporting, compliance, or occupancy management.

Legal and Regulatory Authorities

We may disclose information:

• To comply with laws or legal process

• In response to subpoenas or court orders

• To protect legal rights

• To investigate fraud or security incidents

• To enforce agreements

• To protect safety or property

Business Transfers

Information may be transferred in connection with:

• Mergers

• Acquisitions

• Financing transactions

• Asset sales

• Business reorganizations

• Bankruptcy proceedings

9. Payment Information

Payments may be processed through third-party payment processors.

Empire Luxe Living LLC does not intentionally store complete payment card information on our internal servers unless expressly required for authorized business operations and secured in accordance with applicable security standards.

Third-party payment providers may independently collect and process payment information subject to their own privacy and security policies.

10. Cybersecurity and Information Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against:

• Unauthorized access

• Disclosure

• Misuse

• Alteration

• Loss

• Destruction

• Cybersecurity threats

Our security measures may include:

• Encryption technologies

• Secure hosting environments

• Firewalls

• Access controls

• Role-based permissions

• Multi-factor authentication

• Endpoint protection

• Network monitoring

• Security audits

• Vendor security reviews

• Data minimization practices

• Incident response procedures

• Employee confidentiality obligations

Despite reasonable safeguards, no method of transmission, storage, or cybersecurity protection is guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

11. Data Retention

We retain personal information only for as long as reasonably necessary to:

• Fulfill operational purposes

• Satisfy contractual obligations

• Resolve disputes

• Enforce agreements

• Maintain business records

• Comply with legal, tax, insurance, accounting, regulatory, or security obligations

Retention periods may vary depending on the nature of the information and applicable legal requirements.

12. Your Privacy Rights

Depending on your jurisdiction, you may have rights relating to your personal information, including:

• Right to access

• Right to correction

• Right to deletion

• Right to data portability

• Right to opt out of certain processing

• Right to withdraw consent

• Right to object to processing

• Right to restrict processing

• Right to appeal certain decisions

• Right to opt out of targeted advertising

To exercise privacy rights, contact us using the information below.

We may require identity verification before processing requests.

13. State Privacy Rights

Residents of certain states, including California and other applicable jurisdictions, may have additional privacy rights under applicable laws.

Where applicable, users may have rights relating to:

• Access requests

• Deletion requests

• Correction requests

• Data portability

• Opt-out rights

• Non-discrimination for exercising privacy rights

We reserve the right to verify consumer requests before responding.