Privacy Policy

Last updated: 14 February 2024 


This privacy policy describes how ASG II Hospitality Holdings, LLC, trading as Actabl and its wholly-owned subsidiaries Actabl Services, LLC, ProfitSword, LLC , FivePals, Inc., FivePals UK Ltd., Transcendent Solutions, LLC, and Hotel Effectiveness Solutions, LLC (collectively referred to as "Actabl", "we," "us," or “our” in this policy) will make use of your personal data when you use the website (“Website”), contact us via phone or email, request to receive marketing from us or access our services online (“Services”). Our policy also describes the rights you can exercise concerning our processing of your personal data. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.


While we believe this entire policy is important, and we recommend you read all of it, we want to highlight a few points:


• What personal data do we collect? We collect the following categories of personal data: (1) Identifiers, (2) Customer Records, (3) Geolocation, (4) Internet or Other Electronic Network Activity Information, and (5) Sensitive Personal Information. You can find more details on those categories in the section below.


• How do we use you information? We use your personal data for a variety of purposes, including fulfilling our contract with you, providing you the products or services you request, communicating with you, complying with legal obligations, ensuring the safety and security of our Website, and delivering relevant advertising. 


• Do we sell or share your information? We do not provide your personal data to others in exchange for money. With your consent, we may share personal data with trusted third parties to provide you more relevant advertising. Some jurisdictions consider this a sale or targeted advertising (a practice California refers to as “sharing”).


How long do we keep your information? Except for personal data processed with your consent or for marketing purposes, we retain your personal data for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. If we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

What personal data do we collect?

In the interest of ensuring our customers are fully informed, we outline the types of information we collected in two ways. 

We begin by providing granular details on the type of information we collect:

• your name, username and password;

• email address and phone number;

• your payment and delivery details, including billing and delivery addresses and credit card details, where you make purchases from us;

• your marketing preferences, including any consents you have given us; and

• information related to the browser or device you use to access the Website or Services, such as:

• location information as provided by your device or browser, such as your device's GPS signal or information about nearby WiFi access points;

• your Internet Protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the internet;

• information about your device such as browser type, operating system, and internet service provider; and

• information about your visit to our Website such as pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services.

Next, we explain the data we have collected in the last 12 months using the method California requires. Under the California Consumer Privacy Act, we are required to information California residents about the personal data we collecting using categories specified in that law. (Some of the data points we collect fit into more than one category.) You can see that list below:

• Identifiers. This includes information such as your name, contact information, and account credentials. 

• Customer Records. This includes information such as your name, contact information, and payment details. 

• Geolocation. This includes information about your location that we collect from sources such as your device or browser. 

• Internet or Other Electronic Network Activity Information. This includes information such as network activity information, browsing history, search history, and information regarding your interaction with our Website.

Sensitive Personal Information. This includes your account credentials and payment details.

How do we collect personal data?

We collect and process personal data about you when you interact with us, interact with our Website, and when you use our Services.  Sometimes, we receive information about you from third parties, such as conference organizers or companies who help us fix incomplete contact information. We may also obtain information about you from other third-party services and organizations to enhance your experience.

Why do we use your personal data, and what is our legal basis for our use?

In the last 12 months, we have collected and processed personal data based the following legal bases, and for the associated purposes, described below:

• To fulfill a contract, or take steps linked to a contract. when you make a purchase from us. We use the information for purposes including:

- verifying your identity;

- taking payments;

- communicating with you;

- providing customer services and arranging the delivery or other provision of products or services.

• To conduct our business and pursue our legitimate interests, in particular:

- providing products and services you have requested;

- responding to any comments or complaints you may send to us;

- personalizing our Website, products or Services for you;

- verifying payment information;

- preventing, investigating, and reporting fraud, misrepresentations, security incidents, and potentially prohibited or illegal activities;

- investigating complaints received from you or others about our Website,  products, or Services;

- complying with our legal obligations and protecting our legal rights, such as managing legal claims, conducting audits, responding to subpoenas, and honoring law enforcement requests; 

- operating our business, such as conducting audits, performing administrative tasks, engaging with regulators;

- inviting users to partake in surveys and analyzing the results; and

- protecting the rights, safety, and interests of ourselves and others.

• For purposes which are required by law, such as complying with requests by competent public bodies, judicial authorities, government or law enforcement authorities conducting an investigation.

Additionally, if you consent, we will use your personal data to:

• sending you direct marketing in relation to our relevant products and services, or other products and services provided by us;

• providing customised content and make recommendations that would improve your experience with the Website;

• serving you ads on our own services or elsewhere online that match your inferred interests, preferences, and characteristics;

• sending you content and communications including advertisements and offers, about our own and our trusted partners’ products and services which integrate with our Services;

• placing cookies and use similar technologies in accordance with the information below and the information provided to you when those technologies are used; and

• undertaking other activities that are explained to you when you consent.

For our customers in the United States, we may engage in the activities described above without your consent when consent is not legally required.

We obtain consent, when legally required, for processing sensitive personal data. We also do not process such data for reasons other than those allowed by California Civil Code Section 1798.121(a) and the associated regulations. And we do not use your information for profiling, as that term is defined in applicable privacy laws, in connection with making decisions that have legal or similarly significant effects.

What if I want to withdraw my consent or opt out of direct marketing?

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent when doing so is in our legitimate interests.

You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

When and how do we disclose personal data?

In the last 12 months, we disclosed limited personal data to third parties—which do not include the recipients noted below, such as our vendors or government authorities—for joint marketing campaigns. In connection with those campaigns, we provide contact information such as names and email addresses. 

We provide personal data to our vendors (which some jurisdictions call processors or service providers), who will process the data on our behalf for the purposes identified above.  For example, we provide limited information to vendors who assist us with services such as IT, security, marketing, customer relations, and payment processing. 

We may also disclose your personal data to government authorities and/or law enforcement officials if required for the purposes above, mandated by law, or required for the legal protection of our legitimate interests.

We may disclose your personal data in connection with an actual or proposed change in control, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.  When that occurs, your data may be disclosed to our advisers, prospective or actual purchaser’s advisers, and to the new or prospective owners of the business.

Do we sell personal data or use it for targeted advertising?

We do not provide your information to third parties in exchange for money. With your consent, we allow trusted partners to collect certain information about you when you interact with our Website so that they can provide you targeted advertising based on your online interactions with us and others. Some jurisdictions may also consider this practice as us “selling” or “sharing” your information. In the last 12 months, we allowed companies to collect the following categories of personal data for targeted advertising: Internet and Other Electronic Network Activity Information. We do not have actual knowledge that we allowed those companies to collect information on anyone who is younger than 16 years old. 

If you do not want us to sell or share your data, you can opt out by withdrawing your consent (by changing your cookie preferences on our website) or following the instructions below. Alternatively, you can rely on a universal opt-out signal to tell us you wish to opt out of us selling or sharing your data. We recognize those signals for the browser sending the opt-out signal. (If you later access our website from a different browser without the signal, your opt-out settings will not carry over.) The universal opt-out signals comes in different types, which are often a browser add-on or setting, so we recommend following the instructions for your preferred variation. Once you have properly configured your signal, we will automatically process it in a frictionless manner. In other words, we will not (1) charge you for using it, (2) change your experience with our services, or (3) display pop-ups or other notifications in response to your opt-out signal (except we may display some indicator acknowledging your request).

How do we safeguard cross-border transfers?

If we transfer your Personal Data outside the UK or EEA to a country that is not subject to an adequacy decision by the EU Commission or under the United Kingdom adequacy regulations, we rely on approved standard contractual clauses or Binding Corporate Rules.  A copy of the relevant mechanism can be provided for your review on request to

What are cookies, and how do we use them?

A cookie is a very small text document, which often includes a pseudonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about cookies on In addition to cookies, we also use other forms of technology which serve a similar purpose to cookies, to monitor and improve our website. When we talk elsewhere in this policy about cookies, the term includes these similar technologies.

Our Website uses three types of cookies: required cookies, analytics cookies, and advertising cookies. 

• Required Cookies. These cookies are required to enable our Website’s core functionality. Without these cookies, services you have asked for, like identifying you while you are logged in, cannot be provided. If you disable these cookies, then certain parts of our Website will not function for you.

• Analytics Cookies. These cookies help us improve or optimise the experience we provide. They allow us to measure how visitors interact with our Website and we use this information to improve the user experience and performance of our platforms. These cookies are used to collect technical information such as the number of pages visited, which parts of our website are clicked on and the length of time between clicks. For example, we useto better understand how customers use the Site. If you don’t want Google Analytics to be used in your browser, you can install this Google add-on:

• Advertising Cookies. These cookies collect information about your browsing habits on our Website in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. This information is collected by third parties who help us provide you more relevant online advertising.

You can manage your cookie-consent preferences for our website by clicking here. Your device or browser may offer options for limiting or deleting cookies. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Website does not currently change the way it operates after detecting a “Do Not Track” signal.

What rights do I have concerning my personal data?

Your use of the website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting includes content displayed from a third party website. You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country. A list of the third parties who place cookies on our website are:

  • Facebook
  • LinkedIn
  • Google
  • HubSpot
  • Hotjar
How Do You Manage These Technologies?

If you want to delete any cookies that are already on your device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

To manage your cookie consent preferences, please click here.

We keep information collected from cookies for a maximum of 12 months.

What Rights Do I Have?

Your rights depend on where you are located.

If you are in the EU or UK

You have the right to ask us for a copy of your personal data; to correctdelete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. Additionally, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU or UK data protection authority where you live, work or where you believe a violation of applicable law may have occurred.

If you are not in the EU or UK

You have the right to ask us for a copy of your personal data; to ask for details about our processing (such as what categories of your personal data we have and where we collected it from); to correct or delete your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

Additionally, you have the right to opt out of sales or targeted advertising (sharing). As noted above, we do not “sell” your information in the traditional sense (an exchange for money), but we do disclose it for targeted advertising—which some jurisdictions may consider a sale.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep.

We will not discriminate against you if you exercise those rights. To exercise any of these rights, you can get in touch with us using the details set out below.  You can also have an authorized agent submit a request on your behalf. If you choose to use an agent, and the agent does not have power of attorney under the California Probate Code, we cannot process the request until: 

• The agent provides a copy of your signed permission authorizing the agent to make the request; 

• You verify your identity directly with us; or

• You provide us direct confirmation that you provided the agent permission to submit the request. 

If your authorized agent has a valid power of attorney under California Probate Code sections 4121 to 4130, we may request proof of the power of attorney instead of the above. 

Unless you are requesting to opt out of sales or targeted advertising, we must verify your identity before we honor your request. Normally, we will do this using your email address. But we may request other information as well. If we are unable to verify your identity with the information you provide, we may deny your request or request additional information.

Sometimes we may be unable to fulfill your request. 

If you disagree with our decision, you can file an appeal by contacting us at ]. In the subject line, please write: Data Subject Right Appeal. The body of the email should include: (1) your name, (2) the date of the decision you are appealing, and (3) an explanation for why you disagree with that decision. We will contact you if we need more information.

Will we update this privacy policy?

We reserve the right to update this privacy policy at any time. If those changes are material, we will notify you as required by law.

Contact Us

Actabl is the data controller for your personal data. If you have any questions about how we process your data, or would like to opt out of direct marketing, you can get in touch by emailing us at or by writing to 333 Douglas Road, E., Oldsmar, Florida 34677.