Privacy Policy
Effective Date: [TO BE SET UPON LEGAL APPROVAL] — Version 0.1 (Draft)
⚠️ DRAFT — PENDING LEGAL REVIEW — NOT YET ENFORCEABLE
This document is a working draft prepared for legal counsel review. It does not constitute legal advice and is not binding until reviewed, finalized, and published by The Playpen Enterprises LLC with explicit approval.
1. Who We Are
The Playpen Enterprises LLC (“Playpen,” “we,” “us,” or “our”) operates the website chicago.theplaypen.com (the “Platform”).
Playpen acts as a booking coordinator and charter broker. We are an intermediary that connects renters with independent vessel owners, operators, and licensed captains. Playpen does not own or operate any vessels. All charters are performed by independent owners and operators under their own authority, insurance, and licensing.
2. Information We Collect
Account Information
Name, email address, phone number, and mailing address.
Booking Data
Charter dates, guest counts, vessel preferences, and occasion type (e.g., birthday, bachelor/bachelorette party, corporate outing).
Payment Information
Payment transactions are processed by Stripe. We do not store credit card numbers, CVVs, or full payment account numbers on our servers. Stripe’s handling of your payment data is governed by the Stripe Privacy Policy.
Identity Verification
Government-issued identification documents submitted for identity verification, processed by Stripe Identity. Verification is document-based only— we do not collect selfie images, facial geometry, or any biometric identifiers, in compliance with the Illinois Biometric Information Privacy Act (BIPA).
Captain Credentials
USCG Merchant Mariner Credential (MMC) details, insurance documents, and credential verification records.
Owner/Operator Information
Vessel documentation, insurance certificates, commercial permits, and business entity information.
Waiver & Manifest Data
Signer name, electronic signature image, timestamp, GPS location at time of signing, and device information. Electronic signatures are captured in compliance with the federal Electronic Signatures in Global and National Commerce Act (ESIGN Act) and the Illinois Uniform Electronic Transactions Act (UETA).
Captain Selection Evidence
Records of which captains were presented to the renter, the renter’s selection path, and associated timestamps. This data is collected and retained as required for compliance with USCG Navigation and Vessel Inspection Circular (NVIC) 7-94.
Persons Onboard Classification
Role classification for all persons onboard a charter, including guest, captain, crew, vendor, and host representative designations.
Partner-Hosted Event Data
For events organized by partner hosts: ticket purchases and attendee information collected on behalf of the event partner, who serves as the seller-of-record for their event.
Usage Data
Pages visited, search queries, device type and browser information, IP address, and referring URLs.
Communications
Messages exchanged between renters, vessel owners, and captains through the Platform’s messaging system.
Analytics
Microsoft Clarity session recordings and heatmaps, and Google Analytics (GA4) data including pageviews, session duration, and user interactions. See our Cookie Policy for details.
3. How We Use Your Information
- Facilitate charter bookings and payment processing between renters, owners, and captains.
- Verify captain credentials and vessel compliance with applicable regulations.
- Generate required maritime documentation, including passenger manifests, liability waivers, and compliance packets.
- Provide customer support and respond to inquiries.
- Send transactional communications such as booking confirmations, waiver reminders, and weather alerts.
- Improve the Platform’s functionality, user experience, and service offerings.
- Comply with U.S. Coast Guard regulations and maritime safety requirements.
- Maintain audit trails as required by maritime law, including a minimum 7-year retention period for signed waivers and passenger manifests.
- Process refunds, damage claims, and dispute resolution between parties.
4. Who We Share Information With
Playpen shares information only with processors, operators, and service providers necessary to administer and deliver the booking, subject to confidentiality obligations. We do not sell your personal information.
- Vessel Owners and Operators— booking details and renter contact information for trip coordination.
- Captains— passenger manifests and booking details for assigned charters.
- Service Providers— booking details for confirmed add-on services (catering, entertainment, etc.).
- Partner-Hosted Event Organizers— attendee information for events they organize. The partner serves as seller-of-record for their event.
- Stripe(payment processor) — charter bookings are processed on the Platform’s Stripe account; event tickets are processed on the partner’s Stripe connected account.
- Resend(email provider) — transactional emails including booking confirmations and waiver reminders.
- Twilio(SMS provider) — booking alerts, waiver reminders, and time-sensitive notifications.
- Cloudflare R2(cloud storage) — documents, photos, and uploaded files.
- Google Analytics & Microsoft Clarity (analytics providers) — anonymized usage data.
- Sentry(error tracking) — technical error data only, used to identify and fix software defects.
- Buoy(insurance partner) — per-trip insurance data when insurance is purchased by the renter.
- Law Enforcement or Regulators— when legally required, including responses to subpoenas, court orders, or requests from the U.S. Coast Guard or other regulatory authorities.
5. Illinois-Specific Disclosures
Biometric Information Privacy Act (BIPA)
Playpen does not collect biometric identifiers or biometric information as defined under 740 ILCS 14 (BIPA). Our identity verification process is document-based only. We do not use selfie verification, facial recognition, fingerprint scanning, or any other biometric technology.
Illinois Consumer Fraud and Deceptive Business Practices Act
Our pricing and service descriptions are governed by our Terms of Service. We are committed to transparent, accurate representations of our services and fees.
Electronic Signatures
Electronic signatures on waivers and charter agreements comply with the federal ESIGN Act and the Illinois Uniform Electronic Transactions Act (Public Act 102-0038 / Illinois Electronic Commerce Security Act).
6. Data Retention
We retain your information for the periods described below, or as otherwise required by law:
- Waivers, manifests, and inspection records: 7 years (per maritime attorney recommendation).
- Financial records: 7 years (tax and regulatory compliance).
- Captain credential records: duration of active status plus 3 years after deactivation.
- Booking data: 7 years.
- Analytics data (GA4): 26 months (GA4 default retention).
- Session recordings (Clarity): 30 days (Clarity default retention).
- Account data: retained until you request account deletion, followed by a 90-day grace period before permanent removal (subject to retention requirements above).
7. Your Rights
You may request access to, correction of, or deletion of your personal information by contacting us at support@chicago.theplaypen.com.
Please note that certain data — including signed waivers, passenger manifests, and compliance packets — cannot be deleted during the applicable retention period due to maritime safety and legal requirements.
Corporate and confidential bookings: Enhanced privacy controls are available upon request, including marketing suppression and restricted data access.
8. Cookies and Tracking
We use cookies and similar technologies to operate and improve the Platform. For full details, please see our Cookie Policy.
- Essential cookies: session management and authentication.
- Analytics cookies: Google Analytics (GA4) and Microsoft Clarity.
- No advertising cookies are used at launch.
9. Children’s Privacy
The Platform requires users to be at least 21 years of age to create a renter account and book a charter, and at least 18 years of age for captain accounts.
Minor passengers may be included on a charter with guardian consent, which is captured via the liability waiver. For minor passengers, we collect only the minimum information required for the passenger manifest (name and age).
10. Changes to This Policy
We may update this Privacy Policy from time to time. Each version will be published with an effective date and maintained under version control. Material changes will be communicated via email to all users with active accounts prior to the changes taking effect.
11. Contact
For questions or concerns about this Privacy Policy or our data practices, please contact:
The Playpen Enterprises LLC
Email: support@chicago.theplaypen.com
Phone: (312) 776-3311