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Privacy Policy

Effective Date: March 31, 2026 · Last Updated: March 31, 2026

This Privacy Policy describes how Action Digital (“we,” “us,” or “our”) collects, uses, stores, and protects information in connection with the Action List Builder platform (“ALB” or the “Service”). This policy applies to all users of the Service and to the personal data of campground guests whose reservation information is processed by the Service.

1. Roles and Responsibilities

1.1 Data Controller and Data Processor

Under applicable data protection laws, the campground operator (“Customer”) is the data controller of guest personal information. Action Digital acts as a data processor, processing guest data on behalf of and at the direction of the Customer solely for the purpose of providing the Service.

1.2 Customer Responsibility

The Customer is responsible for ensuring that they have a lawful basis for collecting and processing guest personal information, including obtaining any necessary consents. The Customer is also responsible for responding to data subject access requests, deletion requests, and other rights exercised by individuals whose data is processed through the Service.

2. Information We Collect

2.1 Guest Reservation Data (Processed on Behalf of Customer)

The Service processes guest reservation data provided by the Customer through daily CSV data feeds. This data may include:

  • Guest name (first and last)
  • Email address
  • Phone number
  • Mailing address (street, city, state, postal code, country)
  • Reservation details (arrival date, departure date, reservation status, stay nights, site type, site number)
  • Guest attributes (number of adults, children, pets)
  • Booking information (source, referral code, discount codes, equipment type, VKR status)
  • Calculated fields (Miles Out distance, geographic code)

This data originates from KOA’s reservation management system and is delivered to the Service through an automated data pipeline. The Service does not collect this information directly from guests.

2.2 User Account Data

When an authorized user accesses the Service, we collect:

  • Email address (used as login identifier)
  • Password (stored as a one-way bcrypt hash; we never store plaintext passwords)
  • Login activity (timestamps, session data)

2.3 Technical Data

When you access the Service, our hosting infrastructure may automatically collect:

  • IP address
  • Browser type and version
  • Device type
  • Pages visited and actions taken within the Service
  • Timestamps of access

This data is collected by our hosting provider (Vercel) and is used for security monitoring and performance optimization.

2.4 Constant Contact Integration Data

The Service stores OAuth tokens and account identifiers necessary to synchronize campaign lists with the Customer’s Constant Contact account. The Service also retrieves unsubscribed contact lists from Constant Contact to maintain anti-spam compliance.

3. How We Use Information

3.1 Guest Reservation Data

We use guest reservation data solely to provide the Service to the Customer:

  • Ingesting and storing reservation records for campaign segmentation
  • Calculating geographic distance (Miles Out) from guest postal codes
  • Segmenting guests into campaign lists based on Customer-configured rules
  • Synchronizing campaign lists to the Customer’s Constant Contact account
  • Deduplicating contacts and suppressing unsubscribed guests

We do not use guest reservation data for any purpose other than providing the Service. We do not sell, rent, lease, or share guest data with third parties for their own marketing purposes.

3.2 User Account Data

We use user account data to:

  • Authenticate users and maintain secure sessions
  • Provide access to the Service dashboard and features
  • Communicate with users about Service status and issues

3.3 Technical Data

We use technical data to:

  • Monitor and maintain Service performance and security
  • Diagnose and resolve technical issues
  • Protect against unauthorized access and abuse

4. Data Storage and Security

4.1 Infrastructure

The Service is hosted on the following infrastructure:

  • Application hosting: Vercel (serverless, auto-scaling, SOC 2 compliant)
  • Database: Supabase (PostgreSQL, SOC 2 compliant, data encrypted at rest)
  • Data source: Google Drive (data feed delivery)
  • Email platform: Constant Contact (campaign list synchronization)

All data is stored in data centers located in the United States.

4.2 Security Measures

We implement the following security measures to protect data processed by the Service:

  • Encryption in transit (TLS/SSL for all connections)
  • Encryption at rest (database-level encryption via Supabase)
  • Password hashing (bcrypt with salt)
  • JWT-based session management with secure, HTTP-only cookies
  • Role-based access controls
  • OAuth 2.0 with automatic token refresh for Constant Contact integration
  • Daily automated unsubscribe synchronization for anti-spam compliance
  • Audit logging of all sync operations

4.3 Data Retention

Guest reservation data is retained in the Service’s database for the duration of the Customer’s subscription. The data is refreshed daily through the automated ingestion process. Records older than 36 months are automatically excluded from campaign segmentation (though the underlying data remains in the database for historical reference).

Upon termination of the Customer’s subscription, we will export Customer Data in CSV format within thirty (30) days upon request, and delete all Customer Data from our systems within an additional thirty (30) days, except as required by law.

5. Data Sharing and Disclosure

5.1 Service Providers

We share data with the following categories of service providers solely for the purpose of operating the Service:

  • Hosting providers (Vercel, Supabase) — for application hosting and data storage
  • Constant Contact — for campaign list synchronization (at Customer’s direction)
  • Google — for data feed delivery via Google Drive

5.2 Legal Requirements

We may disclose information if required to do so by law, court order, or governmental regulation, or if we believe in good faith that such disclosure is necessary to: (a) comply with legal process; (b) protect the rights, property, or safety of Action Digital, our users, or the public; or (c) detect, prevent, or address fraud, security, or technical issues.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, Customer Data may be transferred to the acquiring entity. We will provide notice of any such transfer and any choices you may have regarding your data.

5.4 No Sale of Personal Information

We do not sell, rent, or lease personal information to third parties. We do not use guest data for our own marketing purposes or share it with third parties for their marketing purposes.

6. Anti-Spam Compliance

The Service includes the following built-in compliance safeguards:

  • Unsubscribe suppression: Contacts who have unsubscribed from the Customer’s Constant Contact account are automatically excluded from all campaign lists. The unsubscribe list is synchronized daily.
  • Email deduplication: Each campaign list contains at most one entry per email address, preventing duplicate sends.
  • Data freshness: Contacts whose most recent departure was more than 36 months ago are automatically excluded from campaign lists.
  • Future reservation awareness: Contacts with upcoming reservations are excluded from rebook campaigns to prevent irrelevant messaging.

These safeguards support compliance with CAN-SPAM, CASL, and similar legislation. However, the Customer remains solely responsible for overall compliance with all applicable anti-spam and email marketing laws, including maintaining proper consent records and honoring opt-out requests.

7. Individual Rights

7.1 For Campground Guests

If you are a campground guest whose personal information is processed by the Service, your rights regarding that information should be directed to the campground operator (the data controller). The campground operator’s privacy practices and contact information are typically available on their website or at their property.

Upon receiving a verified request from the Customer, we will assist with:

  • Providing access to personal data stored in the Service
  • Correcting inaccurate personal data
  • Deleting personal data from the Service
  • Exporting personal data in a portable format

7.2 For Service Users

If you are an authorized user of the Service, you may:

  • Access and update your account information by contacting us
  • Request deletion of your user account
  • Request information about what data we hold about you

To exercise any of these rights, contact us at system@actionlistbuilder.com.

7.3 California Residents (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete personal information, and the right to opt out of the sale of personal information. As noted above, we do not sell personal information. To exercise your rights, contact us at system@actionlistbuilder.com.

8. Children’s Privacy

The Service is not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. The Service processes reservation data provided by campground operators, which may incidentally include information about minors who are part of a guest’s party (e.g., number of children in a reservation). This data is processed solely for campaign segmentation purposes and is not used to target or market directly to minors.

9. International Data Transfers

The Service is hosted in the United States. If you or the guests whose data is processed by the Service are located outside the United States, please be aware that data will be transferred to, stored, and processed in the United States. By using the Service, the Customer represents that they have a lawful basis for transferring guest data to the United States and that they have provided any required notices to data subjects.

10. Cookies and Tracking

The Service uses essential cookies for authentication and session management. These cookies are strictly necessary for the Service to function and cannot be disabled. The Service does not use advertising cookies, analytics cookies, or third-party tracking technologies. The Service does not track users across other websites.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable laws. When we make material changes, we will update the “Last Updated” date and notify affected Customers via email. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Action Digital
Email: system@actionlistbuilder.com
Website: actionlistbuilder.com

For data protection inquiries related to guest reservation data, please contact the campground operator directly, as they are the data controller responsible for guest information.