Privacy Policy

Privacy Policy

Last updated: March 10, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.


Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to CG Management LLC, 4900 Kuawa Road. For the purpose of the GDPR, the Company is the Data Controller.
  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Hawaii, United States.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Common Ground Kauai, accessible from www.commongroundkauai.com.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Text Messaging

CG Investor Holding LLC respects your privacy. By opting into our SMS messaging service, you agree to the following terms regarding how we handle your data.

  • Data Collection: We will collect your name, email address, mailing address, and mobile phone number when you sign up for SMS updates. This information will be collected via the website contact form, email, rental agreement, or third-party reservation systems.
  • Data Usage: We use your data solely for sending informational messages.
  • Data Security: We protect your data with secure storage measures to prevent unauthorized access.
  • Data Retention: We retain your information if you are subscribed to our SMS service. You may request deletion at any time.

MESSAGE AND DATA RATES MAY APPLY. Your mobile carrier may charge fees for sending or receiving text messages, especially if you do not have an unlimited texting or data plan. Messages are recurring, and message frequency varies.

Contact CG Investor Holding LLC at (844) 544-6826 or admin@commongroundkauai.com for HELP or to STOP receiving messages.

  • Opt-Out: You can opt out of the SMS list at any time by texting, emailing, or replying STOP or UNSUBSCRIBE to admin@commongroundkauai.com or (844) 544-6826. After unsubscribing, you will receive a final SMS to confirm your removal and we will remove your number from our list within 24 hours. You can send HELP for additional assistance.
  • Non-Sharing Clause: We do not share your data with third parties for marketing purposes. CG Investor Holding LLC will not sell, rent, or share collected mobile numbers.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at the Adobe Help Center.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies — Type: Session Cookies. Administered by: Us. Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.
  • Cookies Policy / Notice Acceptance Cookies — Type: Persistent Cookies. Administered by: Us. Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies — Type: Persistent Cookies. Administered by: Us. Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference, to provide You with a more personal experience.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for products, items or services You have purchased or any other contract with Us through the Service.
  • To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
  • For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service and for payment processing.
  • For business transfers: We may share or transfer Your personal information in connection with any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.


Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS.


GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You.
  • Request correction of any incomplete or inaccurate Personal Data We hold about You.
  • Object to processing of Your Personal Data where We are relying on a legitimate interest as the legal basis, or where We are processing for direct marketing purposes.
  • Request erasure of Your Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw Your consent at any time. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise Your rights by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority.


CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following categories of personal information may have been collected from California residents within the last twelve (12) months:

  • Category A: Identifiers — e.g. real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name. Collected: Yes.
  • Category B: Personal information (Cal. Civ. Code § 1798.80(e)) — e.g. name, signature, address, telephone number, financial information. Collected: Yes.
  • Category C: Protected classification characteristics — e.g. age, race, sex, national origin, disability. Collected: No.
  • Category D: Commercial information — e.g. records and history of products or services purchased or considered. Collected: Yes.
  • Category E: Biometric information — e.g. fingerprints, faceprints, voiceprints. Collected: No.
  • Category F: Internet or other similar network activity — e.g. interaction with our Service or advertisement. Collected: Yes.
  • Category G: Geolocation data — e.g. approximate physical location. Collected: No.
  • Category H: Sensory data — e.g. audio, electronic, visual information. Collected: No.
  • Category I: Professional or employment-related information. Collected: No.
  • Category J: Non-public education information. Collected: No.
  • Category K: Inferences drawn from other personal information. Collected: No.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You — from forms You complete, preferences You express, or from Your purchases on our Service.
  • Indirectly from You — from observing Your activity on our Service.
  • Automatically from You — through cookies set on Your Device as You navigate through our Service.
  • From Service Providers — third-party vendors for payment processing or other services.

Use of Personal Information for Business Purposes

We may use or disclose personal information We collect for business or commercial purposes, which may include:

  • To operate our Service and provide You with our Service.
  • To provide You with support and to respond to Your inquiries.
  • To fulfill or meet the reason You provided the information.
  • To respond to law enforcement requests and as required by applicable law.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity.

Disclosure of Personal Information for Business Purposes

We may use or disclose the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Sale of Personal Information

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

We may share Your personal information with the following categories of third parties: Service Providers, payment processors, Our affiliates, Our business partners, and third-party vendors You or Your agents authorize Us to disclose Your personal information to in connection with products or services We provide to You.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service. We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization from either the Consumer (if between 13 and 16 years of age) or the parent or guardian (if under 13 years of age). If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us.

Your Rights under the CCPA

If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. You have the right to request that We disclose information about Our collection, use, sale, and disclosure of your personal information.
  • The right to opt-out. You have the right to direct Us to not sell Your personal information.
  • The right to delete. You have the right to request the deletion of Your Personal Data, subject to certain exceptions.
  • The right not to be discriminated against for exercising any of Your consumer rights.

Exercising Your CCPA Data Protection Rights

If You are a California resident, You can contact Us by email at hello@commongroundkauai.com. Your request must provide sufficient information to verify Your identity and describe Your request in sufficient detail for Us to properly understand and respond to it.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. For data portability requests, We will select a format to provide Your personal information that is readily useable and allows You to transmit the information from one entity to another without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.


“Do Not Track” Policy (CalOPPA)

Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.


Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.


Your California Privacy Rights (Shine the Light Law)

Under California Civil Code Section 1798, California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact Us using the information provided below.


California Privacy Rights for Minor Users

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, please contact Us using the information below and include the email address associated with Your account.


Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.


Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.


Contact Us

If you have any questions about this Privacy Policy, You can contact us: