Privacy policy
Last updated Filone Inc.
Draft for attorney review
This page has not been reviewed or signed off by an attorney. It is written to be redlined rather than relied on: the bracketed items in it mark every point where a real decision is still missing, and they are left visible on purpose.
What we collect, why we collect it, and who we give it to. This site does not take payments yet, so there is not much of it. This page will get longer when bookings go live, and it will be republished before that happens rather than after.
1. Who is responsible
Filone Inc., a Florida corporation trading as Wayrali, at 1900 West Oakland Park Boulevard, Unit 5881, Fort Lauderdale, FL 33310, United States, is responsible for the personal information described here. Write to privacy@wayrali.com.
Operator decision
[NEEDS OPERATOR DECISION: the privacy@wayrali.com mailbox does not exist yet. A privacy contact address that bounces is a compliance failure, not a typo — it is the one address a regulator will test.]
2. What this site collects today
There is no checkout here, no customer account, and no payment processing in operation. Nothing on this site asks you for a name, an address or a card number, so none of that is collected.
What does happen:
- Aggregate page analytics — which pages get read, and roughly how often. Counted in aggregate, not tied to a person.
- Whatever you choose to put in an email you send us, and our reply to it.
- Ordinary web request records kept by our hosting provider.
Operator decision
[NEEDS OPERATOR INPUT: what the hosting provider actually retains in its request records, and for how long, so the list above is complete rather than approximately right.]
3. Cookies
Two cookies. Both ours. Nothing else.
Analytics on this site are aggregate. There are no third-party trackers, no advertising tags, no retargeting pixels and no cross-site identifiers, and the consent banner says exactly that because it is exactly true.
Operator decision
[NEEDS OPERATOR INPUT: the name, purpose and lifetime of each of the two cookies, so the table below carries real values instead of a description of values.]
| Cookie | What it does | How long it lasts |
|---|---|---|
| [NEEDS OPERATOR INPUT: cookie name] | [NEEDS OPERATOR INPUT: purpose] | [NEEDS OPERATOR INPUT: lifetime] |
| [NEEDS OPERATOR INPUT: cookie name] | [NEEDS OPERATOR INPUT: purpose] | [NEEDS OPERATOR INPUT: lifetime] |
Operator decision
[NEEDS OPERATOR DECISION: adding any marketing or analytics tool that sets a non-essential cookie makes the two-cookie claim false and makes the banner wrong at the same moment. If one is added, this section needs a full cookie table, the banner needs real per-category consent, and consent has to be logged. Do not add a tag and leave either as it is.]
4. Who we share it with
Today: our hosting provider, which stores and serves this site, and our email provider if you write to us. Nobody else.
We do not sell personal information. We do not share it with advertising networks or data brokers. We do not run retargeting.
We will also disclose information where a law, a regulator or a court requires it, and we will tell you when we are allowed to.
5. What changes when bookings go live
None of what follows is in operation. It is set out here so that the change is visible when it happens rather than quiet.
Taking a booking will mean collecting a guest name, an email address, the number of guests and payment details, and giving the property the guest name and the stay details so the reservation can be placed in that name. There is no way to reserve accommodation without that last disclosure — it is what makes the booking exist.
Operator decision
[NEEDS OPERATOR DECISION: this policy has to be rewritten and republished before the first booking is taken. The paragraph above describes intent, not practice, and it must not still say that on the day money moves.]
6. How long we keep things
Financial records have a statutory floor. Correspondence and analytics do not, and we would rather choose a period and keep to it than publish one nobody follows.
Operator decision
[NEEDS OPERATOR DECISION: retention periods for booking records, correspondence, abandoned checkouts and analytics. Nothing is stated above until each one is chosen, because a published retention period that is not enforced is worse than none.]
7. Your rights
You can ask for a copy of the information we hold about you, ask us to correct it, or ask us to delete it. Write to privacy@wayrali.com. We will act on it, and where a law sets a deadline for our response we will meet that deadline.
Depending on where you live you may have further rights — under the Florida Digital Bill of Rights, the California Consumer Privacy Act, or a similar state law — including the right not to be treated differently for exercising them. We apply the same practices to everyone regardless of state, because the alternative is maintaining several versions of the truth.
Attorney review
[Attorney review] Whether this business meets the revenue or volume thresholds that trigger the FDBR, the CCPA or another state privacy statute needs confirming. Below the thresholds the paragraphs above are a voluntary commitment; above them they are a compliance obligation carrying specific response deadlines, disclosures, an appeal route and a named contact.
Attorney review
[Attorney review] Two related questions: whether a “Do Not Sell or Share” link is required where nothing is sold or shared, and whether any state-specific notice must be published at this size. Both are cheap to answer now and expensive to discover after launch.
8. Security
Card details will never touch our systems; they go to the payment processor. Everything this site serves is served over HTTPS.
If a breach ever affects personal information we hold, we will tell you what happened, what was exposed and what we are doing about it — within whatever timeframe the law requires, and sooner where we can.
9. Children
This site is not directed at children under 13 and we do not knowingly collect their information.
10. Changes to this policy
If we change this policy, the date at the top changes with it. If a change materially affects information we already hold, we will contact the people affected rather than rely on them re-reading the page.