Privacy Policy

1. Who We Are (Joint Controllers)

North Coast Vacations Inc. (Seychelles IBC #205923) – Platform owner & global data controller – House of Francis, Room 303, Ile Du Port, Mahe, Seychelles

Calisto LLC (Wyoming, USA) – Contracting entity & merchant of record – 30 N Gould St., Ste R, Sheridan WY 82801, USA

Processors (intra-group):

• North Coast Vacations – Dominican Republic – operational support
• North Coast Vacations – Spain – Marketing & Guest Support
• Calisto Philippines – Back-office & Help-desk (cost-plus service centre)

2. Scope of This Policy

This policy applies to all personal data collected via our websites and mobile apps, partner portals and booking engines, communications by email, phone, chat, or direct interaction, and integrated third-party platforms (e.g. Stripe, Booking.com, Microsoft Dynamics).

3. What Personal Data We Collect

We may collect the following categories of personal data:

• Identification & Contact Information – Full name, email address, phone number, postal address
• Transactional & Payment Data – Booking and purchase history, billing address and payment method
• Technical & Usage Data – IP address, device type, operating system, browser, log files, session identifiers
• Professional & Property Data – Property details, ownership, location, service preferences, feedback
• Freelancer & Contractor Data – Professional profile, work history, skills, location, tax identifiers, communication records
• Sensitive Data – We do not knowingly collect sensitive personal data unless required by law or with explicit consent

4. How We Use Your Data

We may use anonymized or aggregated data for statistical analysis and business intelligence. We use your personal data for the following purposes:

• To provide, personalize, and manage our services
• To process reservations, payments, and refunds
• To send administrative or marketing communications
• To provide customer support and resolve disputes
• To improve and secure our systems, websites, and services
• To facilitate freelancer and contractor engagement through Calisto Backstage
• To comply with legal and regulatory obligations

5. How We Collect Your Data

We collect personal data through:

• Direct interactions: registration forms, contracts, surveys, emails, or calls
• Automated technologies: cookies, analytics software, mobile identifiers
• Third-party integrations: property portals, payment processors, channel managers
• Platform onboarding: account creation and profile setup on Calisto One, Agency, Backstage, and Pro

6. Sharing Personal Data

All recipients are required to respect your data rights and comply with confidentiality and security obligations. We may share your data with:

• Intra-group processors listed in Section 1
• Service Providers: IT hosting, CRM platforms, analytics, marketing software, and payment processors
• Business Partners: Agents, brokers, cleaning and maintenance providers, concierge partners
• Freelancers & Contractors: Where necessary to deliver services coordinated through Calisto Backstage
• Legal & Regulatory Authorities: Where required by law or to enforce legal claims
• New corporate owner if we undergo merger/asset sale (with notice)

7. International Data Transfers

We operate globally and may transfer your data outside the European Economic Area (EEA). Our team and contractor network operates across multiple jurisdictions — including but not limited to the United States, the Dominican Republic, Colombia, and the Philippines. These transfers are safeguarded by:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules (BCRs), where applicable
• Data minimization and encryption practices
• Strict access controls and confidentiality agreements

8. Data Security

We take appropriate technical and organizational measures to protect your data, including:

• SSL/TLS encryption across our websites and portals
• Firewalls and secure access protocols
• Role-based access; staff & contractor NDAs
• Multi-factor authentication & least-privilege IAM
• Regular audits and vulnerability assessments

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, including:

• Booking & tax records – 10 years (legal/tax)
• Marketing preferences – Until consent withdrawn
• Guest ID scans (where required) – 12 months or local statutory period
• Support tickets – 3 years from closure
• Freelancer/contractor records – Duration of engagement plus applicable statutory retention period

After this period, your data will be securely deleted or anonymized.

10. Your Rights

You have the following rights under GDPR and other applicable laws:

• Right of Access: Obtain a copy of your data
• Right of Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data under certain conditions
• Right to Restrict Processing: Temporarily halt processing if contested
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing for marketing or legitimate interest
• Right to Withdraw Consent: Opt out of marketing communications at any time

To exercise these rights, email us at alex@calistoco.com.

11. Cookies & Tracking Technologies

We use cookies and similar technologies to ensure site functionality and performance, track and analyze usage trends, and deliver personalized content and offers. You can manage or disable cookies via your browser settings. For more information, please refer to our Cookie Policy.

12. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect data from minors. If you believe we have mistakenly collected data from a child, please contact us so we can delete it immediately.

13. Policy Updates

We may amend this Privacy Policy from time to time. All changes will be posted on our websites with an updated “Last Updated” date. We encourage you to review the policy regularly to stay informed.

14. Contact Us

If you have any questions or concerns regarding this Privacy Policy or how we handle your personal data, please contact:

Email: alex@calistoco.com

Mail (USA): Calisto LLC, 30 N Gould Street, Ste R, Sheridan, WY 82801

Mail (Ireland): Calisto LLC, 77 Camden Street Lower, Dublin, D02 XE80