Privacy Policy

01Who We Are

ELIT VIRTUAL LLC operates the My 5th Star platform — AI automation agents for real estate agencies. We are a Colorado limited liability company.

For EU/UK data protection law purposes: we are the data controller for data collected directly from our website visitors and subscribers, and a data processor for personal data of your leads and clients that you input into the platform.

02Scope

This Policy applies to visitors of my5thstar.com, subscribers to the My 5th Star platform, and anyone who contacts us directly. It does not apply to third-party services you connect to our platform — those operate under their own policies.

03Data We Collect

Account & contact data. Name, email, phone number, company name, job title, and billing information when you register or contact us.

Usage data. Pages visited, features used, session duration, device type, browser, IP address, and referring URL — collected automatically when you use the Service.

Communications data. Emails, WhatsApp messages, and support chat transcripts you send us.

Lead & client data (processed on your behalf). Personal data of your real estate leads and clients that you upload or sync into the platform — names, contact details, property preferences, conversation history. You control what you input; we process it only to deliver the Service.

AI interaction data. Prompts and conversation logs generated by our AI agents within your account, used for quality assurance and accuracy improvement.

04How We Use Your Data

• Providing the Service: operating AI agents, processing leads, sending automated messages, and delivering your subscription
• Account management: creating accounts, processing payments, and providing customer support
• Communications: transactional emails, product updates, and (where consented) marketing messages
• Security & fraud prevention: monitoring for suspicious activity and protecting our platform
• Analytics & improvement: understanding usage patterns to improve the platform — using aggregated, anonymised data where possible
• Legal compliance: meeting obligations under Colorado law, applicable US federal law, and GDPR/UK GDPR for EU/UK users

We do not use your data or your clients' data to train general-purpose AI models accessible to other customers.

05Legal Basis for Processing (GDPR)

For users in the EEA or UK, we rely on the following legal bases under GDPR:

• Contract (Art. 6(1)(b)): processing necessary to deliver the Service you subscribed to
• Legitimate interests (Art. 6(1)(f)): platform security, fraud prevention, and Service improvement — where not overridden by your rights
• Legal obligation (Art. 6(1)(c)): compliance with applicable law
• Consent (Art. 6(1)(a)): for optional marketing communications and non-essential cookies — withdrawable at any time

06Data Sharing & Third Parties

We do not sell, rent, or trade your personal data. We share data only in these circumstances:

• Service providers: trusted sub-processors (cloud hosting, payment processing, email delivery) bound by data processing agreements, prohibited from using your data for their own purposes
• Integrations you authorise: when you connect third-party platforms, data flows as you configure — you control these connections
• Legal requirements: when required by law, court order, or to protect rights, property, or safety
• Business transfers: in the event of a merger or acquisition, subject to equivalent privacy protections

07International Transfers

ELIT VIRTUAL LLC is based in the United States (Colorado). Some sub-processors may be located in other countries. For transfers of EEA/UK personal data outside those regions, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission. You may request details by emailing [email protected].

08Data Retention

• Account data: retained for the duration of your subscription plus 12 months, unless you request earlier deletion
• Lead & client data: retained for 30 days after subscription termination, then permanently deleted
• Analytics data: retained in anonymised form for up to 24 months
• Financial records: retained for 7 years as required by US tax law

09Security

We implement industry-standard technical and organisational measures including:

• Encryption in transit (TLS 1.2+) and at rest (AES-256)
• Role-based access controls for internal staff
• Regular security reviews and vulnerability assessments
• Documented incident response procedures

In the event of a data breach we will notify affected users and, where required, relevant authorities (including EU supervisory authorities within 72 hours under GDPR) without undue delay. No transmission method is 100% secure and we cannot guarantee absolute security.

10Your Rights

Depending on your location, you have the following rights over your personal data:

To exercise any right, email [email protected] with the subject "Data Rights Request". We respond within 30 days. EU/UK users may also lodge a complaint with their local supervisory authority.

11Cookies & Tracking

Our website uses cookies and similar technologies. We use:

• Essential cookies: required for the site to function — cannot be disabled
• Analytics cookies: understand how visitors use the site, anonymised where possible
• Marketing cookies: measure advertising effectiveness — only with your explicit consent

You can manage cookie preferences via our cookie consent banner or your browser settings. Disabling certain cookies may affect site functionality. EU/UK users are presented with a consent banner before any non-essential cookies are set.

12Children's Privacy

The Service is not directed at anyone under 16. We do not knowingly collect personal data from minors. If you believe we have done so inadvertently, contact us at [email protected] and we will delete it promptly.

13California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know: what personal information we collect, use, and disclose
• Right to delete: request deletion of your personal information, subject to certain exceptions
• Right to opt out of sale: we do not sell personal information — this right is automatically honoured
• Right to non-discrimination: we will not discriminate against you for exercising CCPA rights

To submit a CCPA request, email [email protected] with the subject "CCPA Request". We respond within 45 days.

14Changes to This Policy

We may update this Policy at any time. For material changes we will notify you by email or via a prominent platform notice at least 14 days before the change takes effect. The "Last updated" date above always reflects the most recent revision.

15Contact

See also our Terms & Conditions.