Privacy Policy

1. OVERVIEW OF ROY SERVICES

RoY is a behavior-based, user-generated content platform for hotels, restaurants, and similar businesses (“Businesses”). RoY allows Businesses to submit and review documented guest incidents to support operational risk management. RoY does not independently create, verify, or validate user submissions.

2. INFORMATION WE COLLECT

2.1 Information Collected from Businesses

• Business name, contact information, and account credentials.
• Employee names or identifiers authorized to submit incident reports.
• User-generated incident reports, notes, documentation, file uploads, timestamps, and categories.
• Platform usage data, access logs, and device information.

2.2 Information Collected About Guests

Guest information is collected only when submitted by Businesses or voluntarily provided by guests who purchase premium access. Such information may include:

• Guest name and contact information.
• Incident details submitted by participating Businesses.

RoY does not collect or request protected-class information such as race, religion, disability, or immigration status.

3. PROHIBITED DATA CATEGORIES

Businesses are prohibited from submitting:

• Protected-class identifiers (race, gender, national origin, etc.).
• Medical or disability information.
• Immigration status.
• Financial account numbers or payment card information.
• Subjective personal opinions unrelated to behavior.

RoY automatically flags and may remove prohibited categories.

4. HOW WE USE INFORMATION

RoY uses collected information to:

• Operate, maintain, and improve the platform.
• Generate behavior-based risk scores.
• Provide network visibility of incident data among participating Businesses.
• Conduct compliance audits and enforce platform standards.
• Support integrations with property management and reservation systems (e.g., Cloudbeds, SynXis, Resy).
• Communicate with Businesses and premium-access guests.
• Monitor platform security and detect misuse.

RoY does not use data to determine creditworthiness, employment eligibility, or housing eligibility.

5. DATA SHARING AND DISCLOSURE

RoY shares information:

• Between participating Businesses as part of the platform’s core functionality.
• With third-party vendors assisting with hosting, encryption, analytics, or integrations.
• When required by law, regulation, or lawful subpoena.
• With the guest, if the guest holds a qualifying premium membership providing visibility into their own record.

RoY does not sell guest or Business information.

6. FCRA / CCRA NON-APPLICABILITY

RoY is not a Consumer Reporting Agency under the Fair Credit Reporting Act (FCRA) or California Consumer Reporting Agencies Act (CCRA). Data on the platform:

• Is user-generated.
• Is not independently verified by RoY.
• Is not used to determine guest eligibility for housing, employment, or credit.

Businesses are solely responsible for lawful use of incident information.

7. DATA RETENTION

• Incident reports remain in the system for the duration of a Business’s participation.
• Risk scores decay as defined by RoY’s algorithm, except lawsuit-related incidents, which never decay.
• Business account data is retained as required for legal and operational purposes.
• Guest premium-access data is retained until the account is closed.

8. DATA SECURITY

RoY employs industry-standard security measures including:

• Encryption in transit (TLS/SSL) and at rest.
• Role-based access control for Business users.
• Audit logs of incident submissions and account activity.
• Regular security assessments and monitoring.
• Secure data centers for hosting and storage.

Despite safeguards, no system is completely secure; Businesses and guests use RoY at their own risk.

9. BUSINESS RESPONSIBILITIES

Businesses using RoY agree to:

• Submit only accurate, lawful, documented incident data.
• Avoid discriminatory submissions or misuse of guest information.
• Maintain internal authorization controls.
• Comply with all applicable privacy and anti-discrimination laws.

10. CHILDREN’S PRIVACY

RoY is not intended for individuals under 18 years old. No data should be submitted relating to minors except as legally necessary for documented incidents.

11. INTERNATIONAL USE

RoY is designed for use within the United States. Users outside the U.S. are responsible for ensuring compliance with their local laws.

12. CHANGES TO THIS PRIVACY POLICY

RoY may update this Privacy Policy periodically. Material changes will be communicated to participating Businesses. Continued use of the platform constitutes acceptance of updated terms.