ALL ROADS TRAVEL LLC PRIVACY POLICY

Last Updated: September 13, 2022

All Roads Travel LLC, its subsidiaries and affiliates (collectively, “All Roads Travel LLC”, “we”, “our” or “us”) respect the privacy of our users (“you” or “user”). This Privacy Policy (“Policy”) describes how we collect, process, share and safeguard Personal Information we collect from you, or that you provide to us. We may collect information from you or you may provide information to us in connection with your use of our websites, emails, social media sites, apps, and box offices (altogether the “Services”). It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns.

Please read this Policy carefully so that you understand your rights in relation to your Personal Information, and how we will collect, use and process your Personal Information. If you do not agree with this Privacy Policy or any part thereof, you should not access or use any part of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights in relation to your Personal Information as set out in this Policy.

If you are a California resident, please also review our California Resident Privacy Notice at the end of this policy for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law.

1. Personal Information We Collect
   

We collect Personal Information about you from different sources listed below. In this Policy, “Personal Information” means any information related to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).

Information Provided by You

• Account information. When you sign up to become a lead, register for our platform, apply to become a member, purchase an experience, have an experience transferred to you by a friend, or otherwise use the Services, you provide us with Personal Information, such as your name, age, email address, date of birth, telephone number, country, zipcode and password. You may also choose to provide us with Personal Information such as a photo and experience preferences.
• Attendee Information. You may provide information, including name and age, about others who will join you at an experience, including family members and your children.
• Contact information and other information you choose to provide to us. When you contact us via the contact form on our website, via the chat function on our website, via email, via a social media account, or by other means, you provide us with Personal Information, such as your name, email address, telephone number, the contents of your communications, including the content of customer service calls, and the nature of your correspondence with us.
• Support Information. When you request technical support services, we will process your Personal Information such as your name and the contact details you use to contact us, as well as information on the reasons for your support request, and any additional information you may provide in that context.
• Competitions, promotions and surveys. When you participate in competitions, promotions and surveys, you may provide us with specific Personal Information such as contact information, social media handles and the content of any such competitions, promotions, and surveys. If you win a competition, you may provide us with specific Personal Information, including your contact information and social security number, required for us to report your winnings to the IRS.
• Financial Information. If you purchase one of our online experiences or other products, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
• Vaccination and Testing Information. If you want to participate in one of our events, we will ask you to provide proof of vaccination against Covid-19 (i.e. original/copy/picture of vaccination card) or proof of a negative Covid-19 diagnostic test taken within 72-hours before arrival into each venue. If you want to enable our COVID-19 Money Back Guarantee, we may ask you to provide proof of a positive Covid-19 diagnostic test taken within 14 days of the experience start date.
• Information you post.  We collect information you post in a public space on our website or on a third-party social media site.
• Accessibility and Dietary Information.  We may collect details of your health requirements if you have accessibility requirements or dietary requirements when attending experiences.

Information Collected via Automated Means‍

• Identifiers and usage. When you use the Services we and third parties may automatically collect your IP address, advertising identifiers and potentially non-personal information about your device including model, version and operating system.

• Cookie information. We and third parties may automatically collect information about your visit to and use of the Services via cookies (see below in paragraph 3: “How We Use Cookies and Similar Technologies” for more information). The information they collect may include Personal Information, such as your IP address, advertising identifiers, non-personal information about your device including model, version and operating system, the web pages that you visit just before or just after you use our website, as well as information about your interactions with our website, such the time of your visit and where you have clicked.

Information Collected from Other Sources

• Information from third parties. We obtain Personal Information about you from third parties, such our payment processor Stripe.  This information includes transaction information, such as details of payments made, VAT due, and the timings of such payments. We may also receive information about you from third party guest lists, social media sites if you use a social media feature within our websites or apps or post to a social media platform. This information may include your names and email. We may also collect your Covid-19 status and relevant Personal Information to administer admittance to events.

We also collect, use and share aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of our Services to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy.

2. How We Use Personal Information

We will use your Personal Information for one or more of the following purposes:

• Providing you with the Services. We use your Personal Information to operate, maintain and provide you with the Services. In particular we will use your Personal Information to perform our contractual obligation towards you to allow you to create an account, sign-up to receive more information about an event or from a business partner, browse our website, purchase and participate in experiences, maintain a record of such purchase(s), and to contact you in case of any issue with your account. The Personal Information we process when doing so includes your registration, contact, and transaction information.

• Providing you with support and to respond to your requests and complaints. If you reach out to us for support, we will perform our contractual obligation towards you by using your Personal Information to respond and resolve your queries and facilitate support. The Personal Information we process when doing so includes your correspondence with us, your name, contact details, and, to the extent applicable to your query or complaint, transaction and usage information.

• Performing any payments requested by you and executing payment transactions.

• Improve or monitor usage of our Services. It is in our legitimate interests to improve our Services for our users, which includes conducting troubleshooting, testing and research and to keep the Services secure. When doing so we may use Personal Information that we automatically collect about you, such as identifiers and information on use.

• To monitor and analyse trends and use of our Services. It is in our legitimate interests to analyse the use of our Services.  When doing so, we will process Personal Information that we automatically collect about you or that is generated about you when you use the Services.

• To enforce our Terms and Conditions, to comply with legal obligations and to defend All Roads Travel LLC against legal claims or disputes. It is in our legitimate interests to enforce our terms and policies, to ensure the integrity of our Services and to defend ourselves against legal claims or disputes. Where we do so, we will use the Personal Information relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on All Roads Travel LLC, for example to keep records of transactions.

• Marketing. Unless you have opted out of receiving marketing communications, it is in our legitimate interests to use your Personal Information to communicate with you regarding promotions, events, and other news, products or services we think will be of interest to you. You can opt out of such communications when you register an account with us, by following the unsubscribe mechanism, or by otherwise emailing us at <privacy.queries@allroadstravel.com>. We will also share your Personal Information with business partners, including third parties that promote and/or provide an experience. This can include promoters, musicians, artists, sponsors, venues, hotels, and their respective teams. Our business partners use this information in compliance with this Privacy Policy and as described in their privacy policies, which may include sending you marketing communications. To opt out of such communications, please contact the third party business partners.

• Push Notifications.  We may use push notifications and your location information in our apps to send you information and alerts, including about experiences that you are attending.

3. Our Use of European Personal Information

If you are in the European Economic Area (EEA), the UK or Switzerland we only process your Personal Information when we have a valid legal basis.

• Consent. We may use your Personal Information when you have given your consent to do so. For example, to send you marketing communications.

• Contractual necessity. We may use your Personal Information to perform our end of our contracts with you. For example, to provide you with the Services.

• Legal obligation. We may use your Personal Information when we are legally required to. For example, to comply with tax and accounting obligations, or to comply with a court order.

• Legitimate interest. We may use your Personal Information when we, or a third party, have a legitimate interest in doing so. For example, we have a legitimate interest in understanding usage and improving the Services. We only rely on our or a third party’s legitimate interests to process Personal Information when these interests are not overridden by your rights and interests.

4. How We Use Cookies and Similar Technologies 

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive.

Our website uses cookies, beacons, invisible tags, and similar technologies (collectively “cookies”) to collect information about your browsing activities and to distinguish you from other users of our website. This aids your experience when you browse our website and also allows us to improve the functionality of our website.

For more information on how we use cookies and how to change your cookie preferences, please visit our Cookie Policy.

5. Who we Share Your Information With
   

We disclose Personal Information about you with the following recipients and in the following circumstances:

• Vendors and service providers. We rely on vendors and service providers for the provision of our Services, such as:

• Partners such as festival partners, sponsors, and ticketing partners;
• Experience providers such as vendors, venues, hotels, and wristband providers;
• Promoters, artists, and performers;
• Providers of marketing communication and CRM tools, for instance Iterable, Mailchimp, and MailGun;
• Customer experience management providers who help us manage and evaluate our customer experience contracts, such as Zendesk;
• Cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you, such as Amazon Web Services and Datadog;
• Analytics providers who help us to understand our user base and how our Services are used, such as Google Analytics, Segment, and Mixpanel;
• Providers of business communication tools, such as Slack, Asana, and Monday.com;

• Payment processors. We disclose your information to payment processors, such as Stripe in order to receive payment for any purchases that you make in connection with the Services.

• All Roads Travel LLC group. We share Personal Information about you with our affiliates and subsidiaries.

• Legal. Information about our users, including Personal Information, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of All Roads Travel LLC, our users, a third party, or the public. ‍

• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Personal Information as part of that transaction.
  

6. Your Rights and Choices

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Promotional materials. If you do not wish to have your email address or other contact information used by All Roads Travel LLC for marketing purposes to promote our own or our affiliates’ or subsidiaries’ products or services, you can opt out by contacting us as set out in the “Contact Us” section below. If we have sent you a newsletter or promotional email, you may opt-out of receiving them by following the instructions included in each newsletter or communication.

• Accessing, deleting and correcting your information.  You may access or delete any Personal Information that we have about you by visiting the [Data Settings] section of your account via the website or app. You may correct or update your profile information by visiting the [Profile Settings] section of your account via the website. You may contact us as set out in the “Our Contact Information” section below to request access to, correct or delete any Personal Information that we have about you. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Contact Us with any questions at privacy.queries@allroadstravel.com