Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Numero Uno Hospitality Group, all entities that the Numero Uno Hospitality Group manages, the direct and indirect subsidiaries and sister companies of Numero Uno Hospitality Group, Numero Uno Beach House, Kite Puerto Rico, and Numero Uno Pinones

General Manager

Sari Erdos

Data Protection Officer

James Warfield
American Financing Corporation - Tech Department 3045 S Parker Rd Suite 100, Aurora, CO 80014 (866) 750-6551

Personal information

Any information relating to an identified or identifiable individual who accesses our websites via domains at www.numerouno.com or www.kitepuertorico.com, or who accesses associated social media accounts or communicates with Numero Uno via email or conventional mail.

2. Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

Specific Types of Personal Information Collected

Your name, alias, postal address, Internet Protocol address, session ID, email address, and other similar identifiers.


Categories of Personal Information

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual.

Specific Types of Personal Information Collected

Physical characteristics relating to ability or skill level as pertains to bookings made through Numero Uno Watersports or Kite Puerto Rico, description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information collected in the process of securing a reservation or booking.


Categories of Personal Information

Characteristics of protected classifications under California or federal law.

Specific Types of Personal Information Collected

Age or date of birth. Physical disability information collected in association with accommodation requests made during the reservations booking process, or communicated in a contact form, email or through a social media channel.


Categories of Personal Information

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Specific Types of Personal Information Collected

Records of room reservations, dates of travel, purchase amounts, quantities, preferences including accessibility accommodations covered under the Americans With Disabilities Act (ADA), kite boarding and other watersports reservations made through a Numero Uno website or through Kite Puerto Rico.


Categories of Personal Information

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

Specific Types of Personal Information Collected

Usage data from the user’s internet session(s) within Numero Uno (www.numerouno.com) and Kite Puerto Rico (www.kitepuertorico.com) web domains. This includes browser cookies, IP address data, data on specific pages viewed by the user during a session, links clicked, items viewed or saved in an online store or reservation engine, the position of the mouse cursor and/or touch screen interactions throughout the duration of the user’s time spent on either web domain.


Categories of Personal Information

Geolocation data

Specific Types of Personal Information Collected

Data on the specific location of a user’s device (laptop, desktop computer, tablet, or smartphone), including the GPS coordinates of the device, cellular or wireless networks used and identifiers about the internet service provider location associated with a user’s session accessing www.numerouno.com, www.kitepuertorico.com, or affiliated websites used to process reservations transactions, online store purchases, and payment. This collection also includes specific IP address logs.


Categories of Personal Information

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

Specific Types of Personal Information Collected

Employment history and duration, as volunteered during the process of seeking employment with Numero Uno or its affiliated businesses through one of our websites or social media platforms.


Categories of Personal Information

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Specific Types of Personal Information Collected

Time spent on our website may be used to anticipate potential purchasing or reservations decisions made by the user in the future, and may be used for the purposes of remarketing or presenting the user with customized offers based on interests signaled during internet browsing sessions on numerouno.com and kitepuertorico.com

This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services.

3. How Your Personal Information is Collected

  • From cookies on our website.
  • Via our IT systems, including:
  • Reception logs and reservations systems.
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
  • Records of contacts, communications and interactions between a user and the company that may take place outside of the scope of this website or affiliated websites, including communications made via telephone, social media networks, conventional mail and email.

4. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you give consent.

A legitimate interest is when we have a business or commercial reason to use your information, when your rights and interests do not override.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

To provide products and services to you

Our reasons

For the performance of our contract with you or to take steps at your request before entering into a contract


What we use your personal information for

To prevent and detect fraud against you or Us.

Our reasons

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you


What we use your personal information for

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

Our reasons

To comply with our legal and regulatory obligations


What we use your personal information for

Ensuring business policies are adhered to, e.g. policies covering security and internet use

Our reasons

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you


What we use your personal information for

Operational reasons, such as improving efficiency, training and quality control

Our reasons

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price


What we use your personal information for

Ensuring the confidentiality of commercially sensitive information

Our reasons

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations


What we use your personal information for

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

Our reasons

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price


What we use your personal information for

Preventing unauthorized access and modifications to systems

Our reasons

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations


What we use your personal information for

Updating and enhancing customer records

Our reasons

For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products


What we use your personal information for

Statutory returns

Our reasons

To comply with our legal and regulatory obligations


What we use your personal information for

Ensuring safe working practices, staff administration and assessments

Our reasons

To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you


What we use your personal information for

Marketing our products and services to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.

Our reasons

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers


What we use your personal information for

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

Our reasons

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

5. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. But where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell to other organizations not affiliated with Numero Uno Group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at: Sari Erdos
  • Using the “unsubscribe” link in emails or “STOP” number in texts; or
  • We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

  • Our affiliates, including companies within the Numero Uno Hospitality Group;
  • Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, including marketing agencies or website hosts;
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
  • Credit reporting agencies;
  • Our insurers and brokers;
  • Our bank[s];

We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, like potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

7. Personal Information We Sold or Disclosed for a Business Purpose

We have not sold or disclosed to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

8. Where Your Personal Information is Held

Information may be held at our offices and those of the Numero Uno Group, third party agencies, service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products or services to you. Then we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

10. Transferring Your Personal Information Out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or
  • Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: the United States of America.

If you would like further information, please contact Us (see “How To Contact Us” below).

11. Your Rights Under the GDPR

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

12. Keeping Your Personal Information Secure

We use appropriate security measures to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us, toll-free, at (866) 750-6551; or
  • Email us using our contact form; or
  • Write our tech department at:
    American Financing Corp, 3045 S Parker Rd Suite 100, Aurora, CO 80014

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly, you must provide us with:

  • Enough information to identify you
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

14. How to File a GDPR Complaint

We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

15. Changes to This Privacy Notice

This privacy notice was published and last updated on 17 May 2022. We may occasionally change this privacy notice–when we do, we will inform you via our website.

16. How to Contact Us.

Please contact us [and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:

General Manager

Sari Erdos

Mailing Address

American Financing Corp, ℅ Ben
3045 S Parker Rd Suite 100, Aurora, CO 80014

Telephone

(866) 750-6551

E-mail

Contact Us

17. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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