Inspirato® Privacy Policy

For the purpose of this Privacy Policy, when we use the term “Personal Information” we mean any information that can be linked to an identified or identifiable person. Non-Personal Information means information that does not directly identify you. We collect both types of information.

We may collect the following Personal Information:

• Direct identifiers and contact information, including your name, postal/mailing address, phone number, or email address

• Demographic information, including age, location, income range, or birthday

• Account registration information, such as your username and password

• Financial information, such as bank account details, credit card information, etc.

• Real estate information, such as ownership and value of real estate

• Occupational information, such as company information and job title

• Information submitted as part of a support request, survey or comment or forum post

• Information about traveling companions

• Personal preferences relating to travel, dining, and activities, information regarding your interest and use of our Services

• Behavioral or demographic attributes, when tied to Personal Information

• Transactional data based on past purchasing behaviors, when tied to Personal Information

• Data from marketing opt in lists, consumer surveys, or publicly available information

• Unique IDs such as a cookie placed on a computer, mobile or device IDs

• Internet Protocol address (“IP address”) and information derived from IP addresses

• Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of “apps” on mobile devices

• Behavioral data of individuals’ computer or device usage on the Online Services, as defined below, such as advertisements clicked, Websites and content areas visited, and date and time of activities

• Web searches used to locate and navigate to Websites

• Any other information submitted by you that includes information specific to you

We may collect Personal Information from or about you in the following ways:

• By Asking. We may collect some Personal Information from you by asking that you provide it to us. For instance, when you register for our Services, purchase a membership, request a copy of the Inspirato Magazine, book travel online, make or redeem purchases on the Websites, or when you attend an in-person event.

• Call Recording. Telephone calls with Inspirato may be recorded and used for quality assurance.

• Social Networking Sites. If you log into your user account through shared sign-in services (e.g., Facebook Connect), you provide Inspirato with permission to access certain information about you from that social networking site, such as your user profile.

• Enhanced Information. We also may enhance the Personal Information we collect from visitors with other information from third party Data Sources, as defined below.

• Third Party Data Sources. In addition to the information that we collect from you directly, we may receive information about you from third parties, such as our vendors, business partners, our affiliates, data providers, data partners or publicly available sources (“Data Sources”). This may include information from customer lists, memberships, or other information created from a third party’s own technology (such as proprietary modeling or matching technology of other companies).

Our primary purpose in collecting Personal Information about you is to provide you with our Services and for our legitimate business purposes. We may use your Personal Information as set out below:

• For everyday business purposes, such as account management, contract management, administration, corporate governance, and reporting obligations

• To complete or process transactions for you and send you confirmations and receipts

• To fulfill booking requests you have made, plan vacations for you, confirm itineraries you have selected, and suggest products or services we think may interest you

• To recognize or identify you when you return to the Online Services

• To tell you about updates to your account, products, and other services

• To respond to your questions and address feedback, provide you with requested services and/or notify you when we think you may be interested in or eligible for certain services, perform our obligations to you, or perform other actions based on your consent

• To better understand your needs and help improve, develop, and evaluate the Services

• To comply with laws and regulations and legal processes

• To monitor compliance with our policies and procedures, for fraud prevention, to detect and address illegal activities and/or to protect Inspirato and its employees, users, other third parties, and property

• To monitor the usage and performance of the Services, and determine aggregate information and usage patterns

• To advertise and market our products and Services (and those of our partners) to you, for example, to present targeted advertisements on the Websites and other third party websites, in email marketing, and in direct mail marketing

• To analyze the effectiveness of our advertisements, and to determine whether you would be interested in new products or services we may offer

We may disclose your Personal Information with third parties in the following situations:

• Disclosing Your Personal Information with Service Providers. We may disclose your Personal Information with third party service providers in order for those service providers to perform business functions for Inspirato. These services may include, among other things, helping us to provide the Services, such as planning, booking, and providing concierges and activity vendors. Service providers also help us to create or maintain our databases; to research and analyze the people who request products, other services or information from us; to prepare and distribute communications; or to respond to inquiries. Additionally, we may also disclose Personal Information or other marketing information to our third party service providers for executing offline and online marketing campaigns. We may use third party service providers, acting on our behalf, to create and display advertising or other content.

• Sharing Your Personal Information as Required by Law. We may disclose your Personal Information with others as required by, or permitted by, law. This may include disclosing your Personal Information to governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or safety of Inspirato, or another person.

• Affiliates and Business Transition. We may disclose your Personal Information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). We may transfer your Personal Information to a successor entity upon a merger, consolidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. Personal Information may be transferred to parties to the transaction based on our legitimate interest in preparing for and completing the transaction. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Policy.

• Partner Companies. We may disclose your Personal Information to carefully selected outside companies when we believe their products or services may interest you, subject to and where permitted by applicable law. We provide this service as a courtesy to you.

• Blogs, Online Postings, and Testimonials. We may decide to allow individuals to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information you provide in these areas may be read, collected, and used by others who access them.

• De-identified or Aggregate Information. We may aggregate and anonymize Personal Information you provide to us in such a way as to ensure it will no longer be identifiable to you. This data may be used for statistical, analytic, and administrative purposes, including analyzing the traffic and trends of our Online Services, tailoring our Services, or conducting product analysis. We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

• Social Media Platforms and Networks. Some of our Websites have features such as, plugins, widgets, cookies, or and other tools made available by third parties that may result in information being collected or shared between us and the third party for marketing purposes.

• SMS Opt-In Data. Notwithstanding anything to the contrary in this privacy policy, all the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or affiliates.

Legal Basis for Disclosure and Processing of Information

Provision of your Personal Information is both a contractual and statutory obligation. We process your information for the purposes described in this Privacy Policy, based on the following legal grounds:

• With Your Consent: In certain instances, we ask for your consent to process your Personal Information for specific purposes. Provision of your consent in such circumstances is voluntary, and you have the right to withdraw your consent at any time.

• When Pursuing Legitimate Interests: We process your Personal Information for our legitimate interests and those of third parties as further described in this Privacy Policy.

• To Perform a Contract With You: We will process your Personal Information when processing of your Personal Information is necessary for the execution or performance of a contract with you.

• When We Have Legal Obligations: We will process your Personal Information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request.

We use cookies and similar tracking technologies to collect certain information on our Websites both on your browser and mobile device and on mobile applications (collectively the “Online Services”). We also permit certain third parties to use cookies and similar tracking technologies to collect information about our Online Services. The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information (“Technical Data”); (b) information about when and how you access and use our Online Services, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage (“Usage Data”); (c) information about the device you use to access the Online Services, such as device type, device ID, and device/browser settings (“Device Information”); and (d) location of the device used to access the Online Services derived from GPS or WiFi use (“Location Information”).

We may use the following types of cookies on our Online Services:

Cookie Type

Description

Advertising Cookies

We may work with third party online or mobile network advertisers that use cookies to help us manage advertising and measure its effectiveness. These cookies enable third party ad networks to recognize a unique cookie on your computer or mobile device and may be placed by us or our network advertising firm that works with our third party network advertiser. The information that is collected and shared by cookies may be linked to the device identifier of the device you are using to allow us to keep track of all the sites and mobile applications you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our Online Services and third party sites based on those interests.

Analytics Cookies

Analytics cookies allow us to understand more about how many visitors we have to our Online Services, how many times they visit us and how many times a user viewed specific pages within our Online Services. Although analytics cookies allow us to gather specific information about the Online Services that you visit and whether you have visited our Online Services multiple times, we cannot use them to find out details such as your name or address.
We use Google Analytics. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. For more information on how to opt out of Google Analytics tracking across all websites you use, visit: https://tools.google.com/dlpage/gaoptout.

Essential Cookies

These are cookies that our Online Services need in order to function, and that enable you to move around and use the Online Services and features. Without these essential cookies, the Online Services will not perform as smoothly for you as we would like it to and we may not be able to provide the Online Services or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.

Personalization Cookies

Personalization cookies allow you to access our Online Services with certain predefined elements, established through a series of criteria on your computer; these may include language preferences, the type of browser used to access the Online Services, the regional configuration from where the service is accessed, etc.

We may use the information collected through tracking technologies for several reasons, including:

• To make our Online Services and mobile applications easier to use.

• To gather metrics about how users interact with our Online Services and mobile applications.

• For security reasons.

• To provide personalized content. For example, we may store user preferences, your default language, device and browser information, your profile information, which includes the level of your usage of the Online Services and mobile applications, which you visit, so we can identify you across devices and personalize the content you see.

• To improve our Services.

• To advertise to you. We may participate in behavioral-based advertising. This means that a third party may use technology, such as a cookie or a web beacon, to identify you on the Websites so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our Websites or on other websites.

Commercially Recognized Opt Out Signal

Inspirato generally recognizes commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the Services

Depending on where you live, you may have certain rights with respect to your Personal Information. For example, under local applicable laws, including certain states in the United States (e.g., California or Colorado) you may have the rights listed below. Please note that many of these rights are subject to exceptions and limitations. You may have the following rights, subject to certain exceptions:

• Right to Rectification. We rely on you to update and correct your Personal Information. You may modify your account profile by logging into your account. Some Personal Information can also be changed by contacting us using the information in the Section titled “How to Contact Us.”

• Right to Erasure/ Deletion (i.e., the right to be forgotten). Typically, we begin sharing your information within 30 days of the date you register for our Services or join our club. We will continue to use your information as described in this Privacy Policy. You may however request that we delete your Personal Information. All requests must be directed to the contact listed under the Section titled “How to Contact Us” below. We may also decide to delete your Personal Information if we believe your data is incomplete, inaccurate or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete Personal Information it will be removed from our active database; it may take up to 30 days to remove you from certain databases and lists but may only be kept for so long as we have a permissible purpose for processing it. Personal Information may remain in archives where it is not practical or possible to delete it. In addition, we may keep your Personal Information as needed to communicate with you in connection with servicing your account, fulfilling your requests, administering any promotion or program in which you have elected to participate and have not withdrawn your consent, or as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.

• Right of Access. Subject to certain exceptions, you have the right to know whether your Personal Information is being processed, and, where that is the case, to request access to, including a copy of, the Personal Information undergoing processing.

• Right to Data Portability. You have the right to request that we provide the Personal Information which you provided to us in a structured, commonly used and machine-readable format; and you have the right to transmit such Personal Information to another entity.

• Right to Restriction of Processing. You have the right to request that we restrict the processing of your Personal Information.

• Right to Object. You have the right to object to our processing of your Personal Information.

• The Right to Opt Out of the Use of Automated Decision Making Technology. You have the right to opt out and, if applicable, request a review of automated decisions that affect your interests.

• Right to Un-Subscribe from Email. If you decide that you do not want to receive commercial emails from us, you can “opt out” from receiving such emails by clicking on the “unsubscribe” link provided at the bottom of every commercial email. Please note that if you choose to opt out, we will still send you emails relating to specific products or services that you purchase, or emails that we believe are pertinent to any communication that you have sent to us, or the relationship that you may have with us. If you decide at a later time that you would like to receive commercial emails from us, you can opt back into our communication list.

• Right to Prohibit the “Selling” or “Sharing” of Personal Information. Our use of cookies or other tracking technologies is deemed a “sale” or “share” under California law (in this context “sharing” means cross contextual behavioral advertising) of Personal Information. As such, you can opt out of our use of tracking technologies and cookies by clicking the “Do not Sell or Share My Personal Information (Opt out)” button at the bottom of the website.

• The following categories of Personal Information disclosed are considered “sale”/ “share” under California law: direct identifiers and device information.

• The following categories of third parties to whom Personal Information was disclosed are considered “sale”/ “share” under California law: social media platforms and networks.

• Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). You have the right to request the restriction of processing of your sensitive Personal Information. At the current time, however, we do not use or disclose sensitive Personal Information for purposes other than those expressed in this Policy or as otherwise permitted by applicable law.

We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.

If you choose to assert any of these rights under applicable laws, we will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data-protection authority.

Submitting Requests

Only you, or an agent that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access to your Personal Information twice within a 12-month period.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person. Please describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Please note that we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.

Please submit your request by calling us at (844) 682-7526 or by emailing us at privacy@inspirato.com. We will review your request and respond to you as soon as possible and as required by applicable law.

If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. If you are located in the state of Colorado, you may have the right to appeal our decision by contacting us at privacy@inspirato.com. Additionally, you can also contact the Colorado Attorney General if you have any concerns regarding the results of your appeal.

If you designate an authorized agent to submit a request to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:

1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the individual’s behalf.

2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

• Text Messages. You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associated with that number. For more information, please refer to the Inspirato Text Messaging Terms and Conditions.

• Shared Accounts. If you limit your privacy settings on an account that you hold jointly with someone else, your privacy choices will apply to everyone on your account.

• Children. We do not intentionally collect information from, and do not tailor any marketing efforts to, children under 13 years of age. Our Services are offered to customers and users who are of the age 18 years and above. No programs, events, Services or offerings are intended for children under the age of 18.

• Other Websites. The Services may link to third parties’ websites. It is also possible that third parties’ websites or emails may link to the Online Services. We are not responsible for the content or the privacy practices of any such third parties, and information collected by third parties is not governed by this Privacy Policy. We encourage you to read the privacy policies of these websites before transmitting any Personal Information to them.

• Transmission of Data to Other Countries. The Inspirato databases and Services where Personal Information is stored may be located in the United States and in other countries that may have privacy laws that differ from where you live. Data protection and privacy laws vary among countries, with some considered to provide more protection than others. Regardless of where your Personal Information is processed or stored, we apply the protections described in this Privacy Policy. We also comply with certain legal frameworks relating to the cross-border transfer of Personal Information by implementing appropriate contractual or other measures, including but not limited to, the European Union or United Kingdom Standard Contractual Clauses, where required.

We take reasonable and appropriate measures to help keep information secure, and to help prevent from disclosure to individuals who are not described in this Privacy Policy. While we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your Personal Information will remain secure in all circumstances.