Privacy Policy

Recoup is a service of Elzinga Creative Studio, LLC ("Recoup," "we," "us," or "our"). This Privacy Policy describes how we collect, use, and protect personal information in connection with https://recoup-1p8.pages.dev (the "Site") and our rebooking service (the "Service").

Please read this policy carefully. By using the Site or Service, you agree to the practices described here.

1. Who This Policy Covers

This policy applies to two groups:

• Site visitors — individuals who visit https://recoup-1p8.pages.dev, complete our lead or contact form, or otherwise interact with our public website.
• Consumer contacts — past customers of our business clients whose contact information is provided to Recoup by those clients for use in the Service.

2. Information We Collect

2a. From Site Visitors

When you fill out a lead or contact form on our Site, we may collect:

• Name
• Business name
• Email address
• Phone number
• Any other information you choose to provide in the form

We also collect standard technical data through cookies and analytics tools (see Section 8).

2b. From Our Business Clients (About Their Customers)

Our clients — home-services businesses — supply us with contact information about their past customers in order to run rebooking outreach on their behalf. This data may include:

• Customer name
• Email address
• Phone number (mobile and/or landline)
• Service history details needed to personalize outreach

Recoup does not independently collect this information. It is provided to us solely by the client for the purpose of operating the Service.

3. How We Use Information

3a. Site Visitor Data

We use information collected via the Site to:

• Respond to inquiries and sales requests
• Provide information about Recoup's services
• Improve our website and marketing

We do not sell site visitor data to third parties.

3b. Consumer Contact Data (Client-Supplied)

We use consumer contact data exclusively to perform the Service on behalf of the client that supplied it — specifically, to send text messages and emails designed to rebook that client's past customers. We use this data:

• Only for the purpose directed by the client
• Only for the duration of the client engagement
• Not for our own marketing
• Not for building any independent data product or audience

We do not sell, rent, share, or use consumer contact data for any secondary commercial purpose. Recoup acts as a service provider (as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act) for all client-supplied consumer data. The client remains the data controller responsible for lawful collection of that data and for ensuring that outreach is permitted under applicable law.

4. Legal Basis and Client Responsibility

Recoup processes consumer contact data on the instructions of our clients. Our clients represent and warrant to us (in our service agreement) that they have the legal right to share this data and to send marketing communications to the individuals on their lists. We rely on that representation.

If you are a consumer who received a text or email from Recoup on behalf of a home-services business, that business is responsible for your relationship with them. Please contact the business directly with any questions about your relationship with them, or contact us using the information in Section 11 to opt out of Recoup's outreach.

5. SMS and Email Outreach Program

When Recoup sends messages on a client's behalf, consumers may receive text messages and/or emails from or on behalf of that client.

SMS disclosures:

• Message frequency will vary based on your rebooking activity and the client's program.
• Message and data rates may apply depending on your mobile carrier and plan.
• To opt out of text messages, reply STOP at any time. You will receive a one-time confirmation and no further messages.
• For help, reply HELP or contact us at kaden@elzingacreativestudio.com.
• Opting out applies to that specific outreach program. It does not affect messages sent directly by the home-services business outside of Recoup's platform.

Email disclosures:

• Every marketing email sent through our platform includes an unsubscribe link in the footer, as required by the federal CAN-SPAM Act.
• To unsubscribe, click the link in any email or contact us at kaden@elzingacreativestudio.com.

6. Sharing of Information

We do not sell personal information. We may share data in the following limited circumstances:

• Service providers: We may share information with vendors and subprocessors (e.g., SMS delivery platforms, email service providers, cloud hosting) who assist us in operating the Service, under confidentiality obligations and only as necessary.
• The originating client: Data provided by a client may be returned to or reported on within that client's account.
• Legal requirements: We may disclose information if required to do so by law, court order, or government authority, or to protect the rights, safety, or property of Recoup or others.
• Business transfers: If Recoup is acquired or merges with another entity, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

We do not share consumer contact data across different clients' accounts or use it to build cross-client profiles.

7. Data Retention

• Site visitor data is retained as long as needed to respond to your inquiry and for our legitimate business records, typically no longer than two years unless a business relationship continues.
• Consumer contact data is retained only for the duration of the client engagement, plus a reasonable period for backup and legal compliance purposes. Upon termination of a client relationship, consumer data is deleted or returned per the terms of our service agreement.

8. Cookies and Analytics

Our Site uses cookies and similar tracking technologies. This may include:

• Essential cookies necessary for the Site to function
• Analytics tools (such as Google Analytics) that help us understand how visitors use the Site

You can control cookies through your browser settings. Note that disabling certain cookies may affect Site functionality.

We do not use consumer contact data in any advertising or retargeting program.

9. Data Security

We use reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, alteration, disclosure, or destruction. This includes encrypted data transmission and access controls.

No method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we take this obligation seriously and maintain incident response procedures.

10. Consumer Privacy Rights

If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to know what personal information we have collected and how it is used
• Right to delete personal information we hold about you (subject to certain exceptions)
• Right to correct inaccurate personal information
• Right to opt out of sale or sharing — we do not sell or share personal information for cross-context behavioral advertising
• Right to limit use of sensitive personal information (if applicable)
• Right to non-discrimination for exercising your rights

If you are a consumer contact (i.e., you received a message from Recoup on behalf of a business client), the business client is the primary controller of your data. We will cooperate with verified consumer requests to access or delete data we hold. Contact us at kaden@elzingacreativestudio.com with your name and the business that contacted you.

If you are a site visitor, contact us at kaden@elzingacreativestudio.com to exercise any of the rights above.

We will respond to verifiable consumer requests within the timeframes required by applicable law.

Residents of other states may also have privacy rights under emerging state laws. We will honor reasonable requests in good faith regardless of state.

11. Children

The Site and Service are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you believe we have inadvertently collected such information, please contact us and we will delete it promptly.

12. Contact Us

For privacy questions, opt-out requests, or to exercise your consumer rights:

Elzinga Creative Studio, LLC [mailing address to be added before finalization] Email: kaden@elzingacreativestudio.com

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top. Material changes will be communicated via a notice on our Site or by email to known contacts. Continued use of the Site or Service after changes are posted constitutes acceptance of the updated policy.

*This document is a starting draft prepared to save attorney time. It is not legal advice and does not create an attorney-client relationship. Review and finalization by a licensed attorney is required before this policy is published.*