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Privacy Policy

Effective Date: August 19, 2026 · Last Updated: August 19, 2026

1. Who We Are

David Media Group Inc. ("David Media Group," "DMG," "we," "us," or "our") is a New York corporation providing marketing technology and content services to restaurants, hotels, and other hospitality businesses.

David Media Group Inc.

367 St Marks Ave #1200
Brooklyn, NY 11238

Contact: info@davidmediagroup.com

This Privacy Policy explains how we collect, use, disclose, and protect personal information.

2. What This Policy Covers

This Policy applies to:

  • davidmediagroup.com — our company website
  • eliteguests.co and app.eliteguests.co — the marketing site and application for Elite Guests, our SMS guest-retention product for restaurants and hotels
  • Any other website, application, or service that links to this Policy

Elite Guests is a product of David Media Group Inc. It is not a separate legal entity. References to "Elite Guests" in this Policy mean the Elite Guests service operated by DMG.

3. Two Different Roles — Please Read This Section

We handle personal information in two distinct capacities, and your rights differ depending on which applies.

3.1 When we act on our own behalf

For visitors to our websites, prospective customers, and the business owners and staff who purchase and use Elite Guests, we determine why and how personal information is used. In privacy law terms, we act as a business or controller.

3.2 When we act on behalf of our clients

Elite Guests is used by restaurants, hotels, and other hospitality businesses ("Clients") to communicate with their own guests and customers ("Guests").

When a Guest opts in through a Client's Elite Guests QR code, link, or form, that Guest is joining the Client's list — not ours. The Client determines who is contacted, what is sent, and when. We process Guest information only to provide the service, on the Client's documented instructions. In privacy law terms, we act as a service provider or processor, and the Client is the business or controller.

The Client owns its Guest list. The Client may export it at any time and retains it if the Client's subscription ends.

If you are a Guest and you want to access, correct, or delete your information, or stop receiving messages, please contact the business that messaged you. You may also reply STOP to any message to opt out immediately, or contact us at info@davidmediagroup.com and we will assist and route your request to the applicable Client.

4. Information We Collect

4.1 Website visitors

  • Device and browser information, IP address, pages viewed, referring URL, and general activity on our sites
  • Information you submit through contact or inquiry forms, including name, email address, phone number, business name, and your message

4.2 Elite Guests customers (business accounts)

  • Account information: name, business name, business address, email address, phone number, job role
  • Business profile information: locations, hours, brand assets, logos, videos, and content you upload
  • Billing information: billing contact, billing address, and transaction records. Full payment card numbers are collected and stored by our payment processor, not by us.
  • Usage information: logins, features used, messages sent, campaign activity, and support communications
  • Registration information required for A2P 10DLC carrier registration, including legal business name, EIN, business address, and authorized representative contact details

4.3 Guests of our Clients — processed on the Client's behalf

  • Name and mobile phone number
  • The fact, date, time, and content of the consent given, along with IP address and the page URL where consent was submitted
  • Visit-related information the Client records, such as visit date or visit count
  • Message delivery and engagement data, including delivered, failed, opened link, and opt-out status

We do not collect payment card data, government identification, precise geolocation, biometric data, health information, or racial, ethnic, religious, or sexual orientation information from Guests. The Elite Guests service is not designed to receive these categories, and Clients are contractually prohibited from uploading them.

5. How We Use Information

PurposeCategories used
Provide, operate, and maintain the serviceAccount, business profile, usage, Guest data
Deliver SMS messages Clients schedule or triggerGuest name and mobile number, message content
Generate message copy for Client review and approvalBusiness profile, campaign goal
Process payments and manage subscriptionsAccount, billing
Complete A2P 10DLC carrier registrationRegistration information
Provide support and respond to inquiriesAccount, support communications
Maintain security, prevent fraud and abuse, and debug errorsDevice, usage, log data
Meet legal, tax, and regulatory obligationsAccount, billing, consent records
Market our own products to businesses and prospectsWebsite visitor and prospect data

We do not use Guest personal information for our own marketing, to build our own contact lists, or to train artificial intelligence models.

6. Text Messaging and Mobile Information

6.1 The commitment

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

This commitment is absolute and is not qualified by any other provision of this Policy.

6.2 Two separate messaging programs

Guest messaging. When a Guest opts in through a Client's QR code, link, or form, the Guest consents to receive messages from that specific business. The consent names the Client. It is not transferable to us, to any other Client, or to any other business. We send those messages only as the Client's service provider.

Our own marketing. Separately, business owners and prospects may choose to receive SMS from Elite Guests about our products, offers, and updates. That consent names Elite Guests and is entirely separate from any Guest program. Consenting to one never enrolls you in the other.

6.3 For all messaging programs

  • Consent is never a condition of purchase or of receiving any product or service
  • Message frequency varies
  • Message and data rates may apply
  • Reply STOP to opt out, or HELP for assistance
  • We honor opt-out requests promptly, including requests not using the word STOP. A reply such as "please stop texting me" is treated as a valid revocation of consent.

6.4 Consent records

We retain records of each opt-in, including the timestamp, IP address, form URL, and the exact consent language displayed at the time. These records exist to demonstrate consent and are not used for marketing.

7. Who We Share Information With

We share personal information only with service providers who need it to operate the service, and only for that purpose. Each is bound by contract to protect the information and to use it for no other purpose.

ProviderFunctionData involved
Vercel Inc.Website and application hostingTechnical and log data
Supabase Inc.Database and authenticationAccount, business profile, Guest data
Cloudflare, Inc.Media storage and content deliveryUploaded video and image files
Telnyx LLCSMS delivery and carrier registrationGuest name, mobile number, message content
Stripe, Inc.Payment processing and subscription billingBilling contact and transaction data
Groq, Inc.Generation of draft message and reply copy for Client reviewBusiness profile and campaign context

We may also disclose information where required by law, valid legal process, or a governmental request; to protect the rights, property, or safety of DMG, our Clients, or others; or in connection with a merger, acquisition, financing, or sale of assets, in which case we will provide notice before information becomes subject to a different policy.

8. What We Do Not Do

  • We do not sell personal information, and we have not done so in the preceding twelve months.
  • We do not share personal information for cross-context behavioral advertising.
  • We do not share mobile opt-in data or consent records with any third party, as stated in Section 6.1.
  • We do not rent, trade, or license Guest lists, and we do not use one Client's Guest data for the benefit of another Client or for our own purposes.
  • We do not filter, gate, suppress, or screen reviews. Where the service invites a Guest to leave a review, it links directly to the business's public review page, and every Guest receives the same invitation regardless of anticipated sentiment.

9. Google User Data

Where a Client authorizes Elite Guests to connect to that Client's Google Business Profile, we access Google user data solely to display the Client's own business information and reviews within the Client's dashboard, and to publish review replies that the Client composes and approves.

Elite Guests' use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically:

  • We access only the Google account data necessary to provide these features
  • We do not transfer Google user data to third parties except as necessary to provide the service, comply with law, or as part of a merger or acquisition with notice
  • We do not use Google user data for advertising, and we do not sell it
  • We do not allow humans to read Google user data except with the Client's explicit consent, for security purposes, to comply with law, or where the data has been aggregated and de-identified
  • A Client may revoke our access at any time through their Google account permissions or by contacting us, and we will delete the associated data

10. Retention

DataRetention
Guest contact and consent recordsFor the life of the Client's account, then 90 days after termination, unless the Client requests earlier deletion or law requires longer
SMS consent records5 years from the last message sent, to demonstrate consent in the event of a dispute
Account and business profile dataFor the life of the account, then 90 days
Billing and transaction records7 years, as required for tax and accounting purposes
Support communications3 years
Log and diagnostic data12 months

After the applicable period, information is deleted or de-identified. Clients may request earlier deletion of their Guest data at any time.

11. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls limiting employee access to what is needed to perform their role, and monitoring for unauthorized activity.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We make no representation that our safeguards exceed reasonable industry practice.

If we become aware of a breach affecting your personal information, we will notify you and any applicable regulator as required by law, including the New York SHIELD Act.

12. Your Rights

Depending on where you live, you may have the right to:

  • Know what personal information we hold about you and how it is used
  • Access or receive a copy of it in a portable format
  • Correct inaccurate information
  • Delete your information
  • Opt out of sale or sharing (note: we do not sell or share, as stated in Section 8)
  • Not be discriminated against for exercising any of these rights

To exercise these rights, email info@davidmediagroup.com with your request and enough information for us to locate your records. We will respond within 45 days, and may extend once by an additional 45 days with notice. We will verify your identity before acting, typically by confirming control of the email address or phone number on file.

You may use an authorized agent, who must provide proof of authorization.

If you are a Guest of one of our Clients, see Section 3.2. Because the Client controls that data, we will forward your request to the Client and assist in fulfilling it. You can always opt out of messages immediately by replying STOP.

California residents may also request disclosure of the categories of personal information collected, the sources, the business purpose, and the categories of third parties to whom it was disclosed. Sections 4, 5, and 7 provide this disclosure.

13. Cookies and Tracking

Our websites use cookies and similar technologies that are necessary to operate the site, remember your preferences, and understand aggregate usage.

We do not use session replay tools. Where we use analytics or advertising technologies, we will identify them here and provide an opt-out mechanism. You can control cookies through your browser settings; disabling them may affect site functionality.

We honor the Global Privacy Control (GPC) and similar browser-based opt-out signals where technically feasible.

14. Children

Our websites and the Elite Guests service are intended for businesses and adults, and are not directed to children under 16. We do not knowingly collect personal information from anyone under 16.

Clients are contractually prohibited from uploading contact information for individuals they know to be under 16. If we learn we have collected information from a child under 16, we will delete it. Contact info@davidmediagroup.com to report this.

15. Where Information Is Processed

We are based in the United States and process information in the United States. If you access our services from outside the U.S., you understand your information will be transferred to and processed in the U.S., where privacy laws may differ from those of your jurisdiction.

The Elite Guests service is offered to businesses in the United States. SMS delivery is limited to U.S. numbers.

16. Changes to This Policy

We may update this Policy. When we do, we will revise the "Last Updated" date above. For material changes, we will provide notice by email to account holders, or by a prominent notice on our websites, at least 14 days before the change takes effect.

We retain prior versions and will provide a copy on request.

17. Contact Us

David Media Group Inc.

367 St Marks Ave #1200
Brooklyn, NY 11238

info@davidmediagroup.com

This Policy is published at davidmediagroup.com/privacy and eliteguests.co/privacy-policy. Both URLs serve the same document.

© David Media Group. New York City.