Privacy Policy

Last Updated: September 1, 2025

 

Elite Recreational Finance (“We,” “Us,” or “Our”), a financial services company, is committed to protecting the privacy and security of the personal information We collect from You. This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service. These practices are in compliance with the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and the requirements of the Consumer Financial Protection Bureau (CFPB).

We use Your personal information to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

1.1 “Account” means a unique account created for You to access our Service or parts of Our Service.
1.2 “Affiliate” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
1.3 “Authorized Dealer” means a dealer partner that has been specifically designated by Us to receive certain borrower information as outlined in this Privacy Policy.
1.4 “Business”, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ Personal Information and determines the purposes and means of the processing of Consumers’ Personal Information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Information, that does business in the State of California.
1.5 “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
1.6 “Company” (referred to as either “the Company,” “We,” “Us,” or “Our,” in this agreement, refers to ELITE RECREATIONAL FINANCE, LLC, 720 Brooker Creek Blvd, Suite 201 Oldsmar, FL 34677.
1.7 “Consumer”, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
1.8 “Do Not Track” (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
1.9 “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined in the CCPA and CPRA.
1.10 “Service” refers to the Website.
1.11 “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
1.12 “Sensitive personal information” means personal information that reveals a consumer’s: (1) social security, driver’s license, state identification card, or passport number; (2) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (3) precise geolocation; (4) racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) contents of a consumer’s mail, email and text messages unless the business is the intended recipient of the communication; (6) genetic data; (7) biometric information for the purpose of unique identification; or (8) personal information collected and analyzed concerning a consumer’s health or sex life or sexual orientation.
1.13 “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
1.14 “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
1.15 “Website” refers to Elite Recreational Finance, accessible from https://eliterfs.com/
2. Information We Collect About You

2.1 Personal Information

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Bank account information in order to pay for products and/or services within the Website

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

• Date of birth
• Passport or National ID card
• Bank card statement
• Other information linking You to an address

2.2 Usage Data

Usage Data is collected automatically and may include information such as Your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

2.3 Information from Third-Party Social Media Services

When You create an Account, You may log in to use the Website through the following third-party social media services:

• Google
• Facebook
• Instagram
• Twitter
• LinkedIn

If You decide to register through or otherwise grant Us access to a third-party social media service, We may collect Personal Information that is already associated with that account, including, but not limited to, name, email address, contact list associated with that account, and sensitive personal information.

You may also have the option of sharing additional information with Us through Your third-party social media service’s account. If You choose to provide such information during registration or otherwise, You are giving Us permission to use, share, and store it in a manner consistent with this Privacy Policy.

3. How Your Personal Information Is Collected

3.1 Publicly accessible sources (e.g., property records)

3.2 Third parties (e.g., sanctions screening providers, credit reporting agencies, customer reference providers)

3.3 Automated information collection

3.3.1 Door entry systems and reception logs

3.3.2 Automated monitoring of our websites and other technical systems, such as our computer networks and applications

3.4 Our information technology systems

3.2 Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

3.2.1. Cookies or Browser Cookies.  You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
3.2.2. Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

3.2.1 Necessary/Essential cookies

• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

3.2.2 Cookies Policy/Notice Acceptance Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

3.2.3 Functionality Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

3.2.4 Tracking and Performance Cookies

• Type: Persistent Cookies
• Administered by: Third-Parties
• Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
• For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

4. Why We Use Your Personal Information

4.1. To provide and maintain our Service, including to monitor the usage of our Service.
4.2. To manage Your Account. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
4.3. To perform our contract with you or to take steps at your request before entering into a contract.
4.4. To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
4.5. To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. 
4.6. To manage Your requests to Us 
4.7. To deliver targeted advertising to You 
4.8. To comply with our legal and regulatory obligations, including those imposed by the CFPB, GLBA, and FCRA. 
4.9. For our legitimate business interests, such as providing and improving our financial products and services, preventing fraud, and conducting research and analysis. 
4.10. Where you have given consent, including for the processing of sensitive personal information.
4.11. Other purposes permitted by the CCPA, CPRA, and CFPB regulations, such as auditing, debugging, short-term transient use, and performing services on behalf of the business.

5. Who We Share Your Personal Information With

5.1. Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service, to advertise on third party websites to You after You visited our Website, and for payment processing.  
5.2. Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. 
5.3. Lenders for Authorized Dealers: We may share certain borrower information with lenders for purposes related to financing transactions with Authorized Dealers.  
5.4. Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions. 
5.5. Service Providers: We use service providers to help deliver our financial products to you, such as payment processors, IT service providers, and credit bureaus. 
5.6. Law enforcement: Under certain circumstances, We may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities. We may also disclose Your Personal Information in the good faith belief that such action is necessary to:  
5.6.1. Comply with a legal obligation.
5.6.2. Protect and defend the rights or property of the Company.
5.6.3. Prevent or investigate possible wrongdoing in connection with the Service.
5.6.4. Protect the personal safety of Users of the Services or the public.
5.6.5. Protect against legal liability.
5.7. Other users: when You share Personal Information or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed outside. If You interact with other Users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other Users will be able to view descriptions of Your activity, communicate with You and view Your profile.

6. Retention of Your Personal Data

The Company will retain Your Personal Information only for as long as is necessary for the purpose set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

7. Transfer of Your Personal Data

Your Personal Information is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other Personal Information.

8. Categories of Personal Information We Sold or Shared

The categories of Personal Information We have sold or shared with third parties are the same as those listed in Section 2, to the extent permitted by the CCPA, CPRA, GLBA, FCRA, and other applicable laws and regulations.

9. Categories of Personal Information We Disclosed for a Business Purpose

The categories of Personal Information We have sold or shared with third parties are the same as those listed in Section 2, to the extent permitted by the CCPA, CPRA, GLBA, FCRA, and other applicable laws and regulations.

10. How Long Your Personal Information Will Be Kept

We will retain Your Personal Information for as long as necessary to fulfill the purposes for which it was collected, as described in this policy, or as required by applicable laws and regulations, including the CFPB’s record retention requirements.

When it is no longer necessary to retain Your Personal Information, We will securely delete or destroy it.

11. Your Rights Under the CCPA/CPRA

11.1. The right to know what Personal Information is collected about You.

11.2. The right to access Your Personal Information.

11.3. The right to delete Your Personal Information, subject to certain exceptions.

11.4. The right to correct inaccurate Personal Information.

11.5. The right to opt out of the sale or sharing of Your Personal Information.

11.6. The right to limit the use and disclosure of Your Sensitive Personal Information.

11.7. The right to non-discrimination for exercising Your CCPA/CPRA rights.

 

12. How to Exercise Your Rights

To exercise any of Your rights under the CCPA/CPRA, You may:

12.1. Email us at tshields@kelleykronenberg.com.

Please note that you may only make a CCPA/CPRA-related data access or data portability request twice within a 12-month period. If You choose to contact Us directly, You will need to provide:

12.3. Enough information to identify You (e.g., Your full name, address, phone number, email address);

12.4. Proof of Your identity and address (e.g., a copy of Your driver’s license or utility bill); and

12.5. A description of what right You want to exercise and the information to which Your request relates.

 

We are not obligated to make a data access or data portability disclosure if We cannot verify that the person making the request is the Consumer about whom the request pertains. Any Personal Information we collect from You to verify Your identity in connection with Your request will only be used for verification purposes.

13. Opt-Out for Targeted Advertising and Data Sales

13.1. You have the right to opt out of the sale of Your Personal Information and the processing of Your Personal Information for targeted advertising purposes.

13.2. To exercise Your opt-out rights, please email us at tshields@kelleykronenberg.com.

13.3. We will honor Your opt-out request and refrain from selling Your Personal Information or using it for targeted advertising within 15 business days of receiving Your request.

13.4. You may choose to opt out of specific types of data sales or targeted advertising by visiting Our Preference Center. This allows you to customize your privacy choices and exercise greater control over how your personal information is used.

13.5. Some third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

13.5.1. The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

13.5.2. The EDAA’s opt-out platform http://www.youronlinechoices.com/

13.5.3. The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

13.6. You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information. 

 

14. Data Prevention Assessments

14.1. Elite Recreational Finance has conducted data protection assessments for any processing of Personal Information that presents a significant risk of harm to Consumers, as required by the CPRA.

14.2. These assessments evaluate the benefits and risks of Our data processing activities and demonstrate Our commitment to mitigating potential privacy and security risks.

14.3. We regularly review and update Our data protection assessments to ensure ongoing compliance with evolving privacy regulations and industry best practices.

 

15. Data Security Measures

15.1. We implement and maintain reasonable security procedures and practices appropriate to the nature of the Personal Information We collect, use, and disclose. These measures are designed to protect Your Personal Information from unauthorized access, destruction, use, modification, or disclosure.

15.2. Our data security measures include, but are not limited to:

15.2.1. Encryption of Personal Information in transit and at rest;

15.2.2. Multi-factor authentication for access to sensitive systems;

15.2.3. Regular security assessments and penetration testing;

15.2.4. Employee training on data protection and security best practices;

15.2.5. Access controls and monitoring to prevent unauthorized access to personal information;

15.2.6. Incident response and data breach notification procedures.

15.3. While We strive to protect Your Personal Information, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of Your Personal Information.

16. Consent Management

16.3. For processing of Sensitive Personal Information, We will obtain Your affirmative consent (opt-in) before collecting or using such information, except where permitted by law without explicit consent.

16.4. You may withdraw Your consent at any time, and We will honor Your request promptly, subject to legal and contractual restrictions.

 

17. Changes to This Privacy Policy

17.1. We may update this privacy policy from time to time to reflect changes in Our data practices, legal requirements, or improvements in Our privacy and security measures.

17.2. We will notify You of any material changes by posting the updated policy on Our Website and, if required by law, obtain Your consent.

17.3. We encourage You to review this Privacy Policy periodically to stay informed about Our information practices and Your privacy rights.

 

18. Regular Policy Review and Updates

18.1. Elite Recreational Finance is committed to regularly reviewing and updating this Privacy Policy to ensure ongoing compliance with changing laws and regulations, as well as to reflect any changes in Our Personal Information practices.

18.2. We conduct a comprehensive review of this policy at least annually, or more frequently if required by significant changes in applicable laws or our business practices.

18.3. Our review process includes:

18.3.1. Consultation with legal experts specializing in privacy and financial services regulations;

18.3.2. Assessment of new or updated regulatory requirements;

18.3.3. Evaluation of feedback received from consumers and regulatory bodies;

18.3.4. Analysis of industry best practices and emerging privacy trends.

18.4. We will promptly update this policy to address any gaps or areas for improvement identified during our review process.

 

19. Contact Us

If you have any questions or concerns about our privacy practices or this policy, please email us at tshields@kelleykronenberg.com.

 

20. Effective Date and Version Control

20.1. This privacy policy is effective as of September 1, 2025.

20.2. Version: 2.0

20.3. Previous versions of this policy are archived and available upon request.

 

By using Our Services, You acknowledge that You have read and understood this Privacy Policy and agree to the collection, use, and disclosure of Your Personal Information as described herein.

 

Elite Recreational Finance

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