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THE DATA WE COLLECT, HOW IT'S USED, AND WHO WE SHARE IT WITH



We care about your privacy and want to help you understand how we collect, use,
and share your personal information



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PRIVACY POLICY

Information We Collect
How We Use Personal Data
How We Share and Disclose Personal Data
Data Retention
Update Your Information
Children's Privacy
California Privacy Rights Disclosures
EEA and UK Users
International Transfers
Health Services
Links to Other Websites


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WE'RE TAKING A DIFFERENT APPROACH TO PRIVACY

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PRIVACY POLICY


EFFECTIVE DATE:FEBRUARY 21, 2023

Welcome to the Privacy Policy of AllTrails, Inc. (“AllTrails,” “we,” “us,” or
“our”). AllTrails provides a digital platform that helps people explore the
outdoors with a collection of detailed, hand-curated trail maps, trail reviews,
and photos crowdsourced from a community of registered hikers, mountain bikers,
and trail runners. This Privacy Policy applies to the following services
operated by AllTrails (collectively, the “Service”):

 * www.alltrails.com and other websites owned and/or operated by AllTrails that
   contain a link to this Privacy Policy (collectively, the “Site");
 * All mobile applications that contain a link to this Privacy Policy (the
   “AllTrails Apps”); and
 * All services made available by AllTrails through the Site and the AllTrails
   Apps, collectively, the “Service”.

This Privacy Policy explains what Personal Data (defined below) we collect, how
we use and share that data, and your choices concerning our data practices.

This Privacy Policy constitutes an integral part of our Terms of Service,
accessible at: https://www.alltrails.com/terms.

Please read this Privacy Policy before using our Service or submitting any
Personal Data to AllTrails and contact us if you have any questions.


INFORMATION WE COLLECT

When you contact us or interact with our Service, we collect information that
alone or in combination with other information could be used to identify you
(“Personal Data”) as follows:

 * Personal Data You Provide to Us: We collect Personal Data when you sign up
   for our Service through the Site or an AllTrails App. The Personal Data
   collected during these interactions may vary based on what you choose to
   share with us, but it may include any of the following:
   * Account Data: When you sign up, some information is required to create an
     account on our Service, such as your name, username, email address, and
     mailing address.
   * Payment Data: If you choose to purchase a subscription to our Service via
     credit card, debit card or other payment method, our third party payments
     processor (Stripe, Inc. or “Stripe”) will process certain payment and
     billing information, such as billing address, payment card details, and
     authentication features. That information is collected by Stripe directly,
     and we do not collect or store it. If you have questions about how Stripe
     protects such information, please read Stripe’s services agreement and
     privacy policy.
   * Social Media Data: We have pages (“Social Media Pages”) on social media
     sites like Facebook, Instagram, Pinterest, Twitter, and LinkedIn (each a
     “Social Media Site”). The platforms that host our Social Media Pages or
     Social Media Features may provide us with aggregate information and
     analytics regarding the use of our Social Media Pages and Social Media
     Features.
   * User Generated Content: User-generated content, such as profile pictures,
     photos, images, videos, posts, comments, questions, messages, user
     interactions, and other content or information that you generate, transmit,
     or otherwise make available on the Service, as well as associated metadata.
     Metadata includes information on how, when, where and by whom a piece of
     content was collected and how that content has been formatted or edited.
     Metadata also includes information that users can add or can have added to
     their content, such as keywords, geographical or location information, and
     other similar data.
   * Contacts Book Data: Our mobile applications may allow you to synchronize
     the numbers in your Contacts address book on a regular basis in order to
     identify any friends and/or relatives who use the Service. When you do so,
     we will ensure that the relevant data is encrypted and will not use it for
     any purpose other than matching your contacts to users of the Service. If
     any of your contacts are using the Service, we will let you know so that
     you can connect with them. You can revoke our access to your Contacts
     address book at any time through your mobile device settings.
   * Additional Information: To help improve your experience or enable certain
     features of the Service, you may choose to provide us with additional
     information, such as your date of birth/age, height, weight, gender,
     profile picture, city of residence, community username, statistics on your
     hiking and biking history and your reviews and photographs of trails.
 * Information We Generate From Your Use of Our Service: When you visit, use,
   interact and register with the Service, we may automatically generate certain
   information about your visit, use, interactions or registration. For example,
   we may monitor the number of people that visit our Site or AllTrails Apps,
   peak hours of visits, which page(s) are visited on our Site or AllTrails
   Apps, the domains our visitors come from (e.g., google.com, yahoo.com, etc.),
   and which browsers people use to access and visit our Site (e.g., Firefox,
   Microsoft Internet Explorer, etc.), broad geographical information, and Site-
   and AllTrails App-navigation pattern. In particular, the following
   information is created and automatically logged in our systems:
   * Log Data: Information that your browser automatically sends whenever you
     visit the Site or AllTrails Apps. Log data includes your IP address (so we
     understand which country you are connecting from when you visit the Site or
     AllTrails Apps), browser type and settings, the date and time of your
     request, and how you interacted with the Site or AllTrails Apps.
   * Cookies Data: We use cookies and similar technologies to operate and
     administer our Site and AllTrails Apps, make it easier for you to use the
     Site and AllTrails Apps during future visits, and gather usage data on our
     Site and AllTrails Apps. For more information about the technologies used
     and information collected on our Site and AllTrails Apps, please refer to
     our Cookie Policy, which forms part of this Privacy Policy.
   * Device Data: Includes the model of the device, operating system, and
     browser you are using. Information collected may depend on the type of
     device you use and its settings. We may also collect data from your device
     to estimate a variety of metrics like the time, frequency and duration of,
     and calories burned during, your activities for the purpose of calculating
     your Usage and Activity Data (described below).
   * Usage and Activity Data: We collect information about how you use our Site
     and AllTrails Apps, such as the types of content that you view or engage
     with, the features you use, the actions you take, and the time, frequency
     and duration of, and calories burned during, your activities.
   * Geolocation Data: If you have enabled location services for an AllTrails
     App on your mobile device or on your computer via the Site, we may collect
     your precise location information based on city, state, zip code, country,
     latitude and longitude. AllTrails may also derive your approximate location
     from the IP address of your computer or mobile device. Geolocation data is
     used for purposes of directing you to nearby trails and parks and offering
     other relevant content and services.
 * Information We Receive From Third Parties. If you elect to authenticate to
   our Service using your account on another service (such as a Facebook,
   Google, or Apple account), we may receive from the other service information
   like your external account name as well as other information you may choose
   to make available to us based on your external account settings, such as
   contact lists and profile photos (if any). You can stop sharing the
   information from the other service with us by removing our access to that
   other service.


HOW WE USE PERSONAL DATA

We use your Personal Data for a variety of purposes, which are listed in the
table below. If we need to use your Personal Data for an unrelated purpose, we
will update this Privacy Policy to explain any such new purpose.

In addition, in respect of each of the purposes for which we use your Personal
Data, privacy laws in certain jurisdictions require us to ensure that we have a
legal basis for that use. Most commonly, we will rely on one of the following
legal bases:

 * Where we need to process your Personal Data to deliver our Service to you, or
   to otherwise perform our contractual obligations to you (“Contractual
   Necessity”).
 * Where we need to process your Personal Data for our legitimate business
   interests, and your interests and fundamental rights do not override those
   interests (“Legitimate Interests”).
 * Where we need to process your Personal Data to comply with a legal or
   regulatory obligation (“Compliance with Law”).
 * Where we have your specific consent to carry out the processing for the
   purpose in question (“Consent”).

We have set out below, in a table format, the various purposes and legal bases
we rely on in respect of the processing of your Personal Data:

Purpose

Legal Basis

Account creation - to create and manage your account on the Service.

Contractual Necessity

Service delivery - to operate and deliver our Service to you.

Contractual Necessity

Lifeline Group - to communicate with your Lifeline Notification Group regarding
your whereabouts as described on our Service.

Contractual Necessity

Payments processing - to process your payments via our third-party payments
processor.

Contractual Necessity

Customer support - to deliver customer support to you and respond to your
queries.

Contractual Necessity

Contacts syncing – to match the phone numbers in your Contacts address book to
users of the Service, if you have chosen to do so.

Contractual Necessity

Service improvement – to analyze how you use our Service and to improve it.

Contractual Necessity

Fraud prevention – to keep our Service and associated systems operational and
secure.

Contractual Necessity

Legal compliance – to comply with our legal obligations, for example our
accounting and tax reporting obligations.

Compliance with Law

Marketing – to send you information about our products and services (including
via email).

Consent

Purpose

Account creation - to create and manage your account on the Service.

Legal Basis

Contractual Necessity

Purpose

Service delivery - to operate and deliver our Service to you.

Legal Basis

Contractual Necessity

Purpose

Lifeline Group - to communicate with your Lifeline Notification Group regarding
your whereabouts as described on our Service.

Legal Basis

Contractual Necessity

Purpose

Payments processing - to process your payments via our third-party payments
processor.

Legal Basis

Contractual Necessity

Purpose

Customer support - to deliver customer support to you and respond to your
queries.

Legal Basis

Contractual Necessity

Purpose

Contacts syncing – to match the phone numbers in your Contacts address book to
users of the Service, if you have chosen to do so.

Legal Basis

Contractual Necessity

Purpose

Service improvement – to analyze how you use our Service and to improve it.

Legal Basis

Contractual Necessity

Purpose

Fraud prevention – to keep our Service and associated systems operational and
secure.

Legal Basis

Contractual Necessity

Purpose

Legal compliance – to comply with our legal obligations, for example our
accounting and tax reporting obligations.

Legal Basis

Compliance with Law

Purpose

Marketing – to send you information about our products and services (including
via email).

Legal Basis

Consent

Marketing. We may contact you to provide information we believe will be of
interest to you. For instance, if you elect to provide your email address, we
may use that information to send you promotional information about our products
and services. If we do, we will only send you such emails if you consent to us
doing so at the time you provide us with your Personal Data. You may opt out of
receiving emails at any time by following the instructions contained in each
promotional email we send you or by contacting us. If you unsubscribe from our
marketing lists, you will no longer receive marketing communications but we will
continue to contact you regarding our Site and Services and to respond to your
requests.


HOW WE SHARE AND DISCLOSE PERSONAL DATA

In certain circumstances, we may share your Personal Data with third parties
without further notice to you, unless required by the law, as set forth below:

 * Affiliates: Other companies in our corporate group may help us deliver our
   Service to you.
 * Vendors and Service Providers: To assist us in meeting business operations
   needs and to perform certain services and functions, we may share Personal
   Data with service providers, including hosting, cloud services and other
   information technology services providers; email communication software
   providers and email newsletter providers; data base and sales services;
   customer relationship management, customer engagement, and customer feedback
   services; payment processors; security services; and analytics services.
   Pursuant to our instructions, these parties will access, process or store
   Personal Data in the course of performing their duties to us.
 * Business Transfers: If we are involved in a merger, acquisition, financing
   due diligence, reorganization, bankruptcy, receivership, sale of all or a
   portion of our assets, or transition of service to another provider, your
   Personal Data and other information may be shared in the diligence process
   with counterparties and others assisting with the transaction and transferred
   to a successor or affiliate as part of that transaction along with other
   assets.
 * Legal Requirements: If required to do so by law or in the good faith belief
   that such action is necessary to (i) comply with legal or regulatory
   obligations, including to respond to lawful requests from public authorities
   and to meet national security or law enforcement requirements, (ii) protect
   and defend our rights or property, (iii) prevent fraud, (iv) act in urgent
   circumstances to protect the personal safety of users of the Site, or the
   public, or (v) protect against legal liability.
 * Other Users. Your profile and other User Generated Content (except for
   private messages) may be visible to other users of the Service (which may
   include all users of the Service or a limited number of users, depending on
   your privacy settings). For example, other users of the Service may have
   access to your information if you chose to make your profile or other
   personal information available to them through the Service, and may also have
   access to content that you submit to the Service such as when you provide
   comments, reviews, survey responses, or share other content. This information
   can be seen, collected and used by others, including being cached, copied,
   screen captured or stored elsewhere by others (e.g., search engines), and we
   are not responsible for any such use of information.


DATA RETENTION

We keep your Personal Data for as long as reasonably necessary for the purposes
described in this Privacy Policy, while we have a legitimate business need to do
so, or as required by law (e.g. for tax, legal, accounting or other purposes),
whichever is the longer.

If you have elected to receive marketing communications from us, we retain
information about your marketing preferences until you opt out of receiving
these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will
consider the amount, nature, and sensitivity of the Personal Data, the potential
risk of harm from unauthorized use or disclosure of your Personal Data, the
purposes for which we use your Personal Data and whether we can achieve those
purposes through other means, and the applicable legal requirements.


UPDATE YOUR INFORMATION

If you need to change or correct your Personal Data, please contact us at
privacy@alltrails.com. We will address your request as required by applicable
law. 


CHILDREN'S PRIVACY

Our Service is not directed to children who are under the age of 16. AllTrails
does not knowingly collect Personal Data from children under the age of 16. If
you have reason to believe that a child under the age of 16 has provided
Personal Data to AllTrails through the Service, please contact us and we will
endeavor to delete that information from our databases.


CALIFORNIA PRIVACY RIGHTS DISCLOSURES

Collection, Disclosure, and Use of Personal Data</strong>: The categories of
Personal Data we have collected in the preceding 12 months are described above
in the “Information We Collect” section. In the preceding 12 months, we have
disclosed for business purposes each of the categories identified in that
section to the categories of third parties identified in the “How We Share and
Disclose Personal Data” section. The business and commercial purposes for
collecting Personal Data are described in the “How We Use Personal Data”
section. We collect Personal Data directly from you and from external accounts
you use to log-in to the Service.

Privacy Rights: Where provided for by law and subject to any applicable
exceptions, California residents may have the following rights under the
California Consumer Privacy Act of 2018 (“CCPA“):

 * To know the categories of Personal Data that AllTrails has collected about
   you, the business purpose for collecting your Personal Data, and the
   categories of sources from which the Personal Data was collected.
 * To access the specific pieces of Personal Data that AllTrails has collected
   about you.
 * To know whether AllTrails has disclosed your Personal Data for business
   purposes, the categories of Personal Data so disclosed, and the categories of
   third parties to whom we have disclosed your Personal Data
 * To have AllTrails, under certain circumstances, delete your Personal Data;
   and
 * To be free from discrimination related to the exercise of these CCPA rights.

AllTrails does not sell your Personal Data

If you would like to exercise any or all of these rights, you may do so by
clicking “Make a Privacy Request” or contacting privacy@alltrails.com. Your
authorized agent may submit requests in the same manner. Once we receive your
request, we will verify your identity by sending an email to the email address
you provide to us.

If you have questions about your rights or our disclosures under the CCPA, or to
request access to an alternative format of this notice, you may reach us at
privacy@alltrails.com.

Online Tracking and Do Not Track Signals: We and our third party service
providers, including Facebook, may use cookies, pixels, or other tracking
technologies to collect information about your browsing activities over time and
across different websites following your use of the Site and use that
information to send targeted advertisements. Our Site currently does not respond
to “Do Not Track” (“DNT”) signals and operates as described in this Privacy
Policy whether or not a DNT signal is received. If we do respond to DNT signals
in the future, we will describe how we do so in this Privacy Policy.


EEA AND UK USERS

Scope: This section applies to users located in the European Economic Area
(“EEA”) or the United Kingdom (“UK”).




Data Controller: AllTrails, Inc. is the data controller for the processing of
your Personal Data. You can find our contact information in the "Contact Us"
section below.




EEA + UK Representatives. For requests, inquiries or issues related to our
processing of your Personal Data and/or this Privacy Policy, users in the EEA or
UK may contact our appointed representatives at their contact information below.

Per Article 27 of the GDPR, we have appointed a European Union (“EU”)
Representative to act as our data protection agent. Our nominated EU
Representative is:




Instant EU GDPR Representative Ltd.

Adam Brogden contact@gdprlocal.com

Tel +353 15549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2, 12A Lower Main Street, Lucan Co. Dublin

K78 X5P8

Ireland




Per Article 27 of the UK Data Privacy Act, we have appointed a UK Representative
to act as our data protection agent. Our nominated UK Representative is:




GDPR Local Ltd.

Adam Brogden contact@gdprlocal.com

Tel +44 1772 217800

 1st Floor Front Suite 27-29 North Street, Brighton

England

BN1 1EB




Legal Bases for Processing. This Privacy Policy (the “How We Use Personal Data”
section) describes the legal bases we rely on for the processing of your
Personal Data. Please contact us if you have any questions about the specific
legal basis we are relying on to process your Personal Data.

Your Rights. Pursuant to applicable privacy laws in the EEA and the UK, you have
the following rights in relation to your Personal Data, under certain
circumstances:

 * Right of access: If you ask us, we will confirm whether we are processing
   your Personal Data and, if so, provide you with a copy of that Personal Data
   along with certain other details.
 * Right to rectification: If your Personal Data is inaccurate or incomplete,
   you are entitled to ask that we correct or complete it. If we shared your
   Personal Data with others, we will tell them about the correction where
   possible. If you ask us, and where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so you can contact them
   directly.
 * Right to erasure: You may ask us to delete or remove your Personal Data, such
   as where you withdraw your consent. If we shared your data with others, we
   will tell them about the erasure where possible. If you ask us, and where
   possible and lawful to do so, we will also tell you with whom we shared your
   Personal Data with so you can contact them directly.
 * Right to restrict processing: You may ask us to restrict or ‘block’ the
   processing of your Personal Data in certain circumstances, such as where you
   contest the accuracy of the data or object to us processing it (please read
   below for information on your right to object). We will tell you before we
   lift any restriction on processing. If we shared your Personal Data with
   others, we will tell them about the restriction where possible. If you ask
   us, and where possible and lawful to do so, we will also tell you with whom
   we shared your Personal Data so you can contact them directly.
 * Right to data portability: You have the right to obtain a copy of your
   Personal Data from us, to the extent that it is processed by automated means.
   We will give you a copy of your Personal Data in a structured, commonly used
   and machine-readable format. You may reuse it elsewhere.
 * Right to object: You may ask us at any time to stop processing your Personal
   Data, and we will do so:
   * If we are relying on a Legitimate Interest to process your Personal Data --
     unless we demonstrate compelling legitimate grounds for the processing or
     we need to process your Personal Data in order to establish, exercise, or
     defend legal claims.
   * If we are processing your Personal Data for direct marketing -- we may keep
     minimum information about you in a suppression list in order to ensure your
     choices are respected in the future and to comply with data protection laws
     (such processing is necessary for our and your legitimate interest in
     pursuing the purposes described above).
 * Right to withdraw consent: If we rely on your Consent to process your
   Personal Data, you have the right to withdraw that consent at any time.
   Withdrawal of consent will not affect any processing of your Personal Data
   before we received notice that you wished to withdraw consent.
 * Right to lodge a complaint with the data protection authority: If you have a
   concern about our privacy practices, including the way we handled your
   Personal Data, you can report it to your local data protection authority.

Typically, you will not have to pay a fee to exercise your rights. However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive, or we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your Personal Data. This is a security
measure to ensure that your Personal Data is not disclosed to any person who has
no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month of receipt.
Occasionally, it may take us longer than a month if your request is particularly
complex or if you have made a number of requests. In this case, we will notify
you and keep you updated.

Please see the "Contact Us" section below for information on how to exercise
your rights.


INTERNATIONAL TRANSFERS

AllTrails is based in the United States. Some of our vendors and service
providers may also be located in the United States or another country. As such,
any processing of your Personal Data may involve an export of your Personal Data
outside of your country of residence, including to countries which may have data
protection laws that are less stringent than the laws in effect in the country
in which you are located. Whenever we transfer your Personal Data out of your
country of residence, we ensure a similar degree of protection is afforded to it
by implementing appropriate safeguards which comply with applicable privacy
laws. If you would like to receive more information about these safeguards,
please contact us.


HEALTH SERVICES

Our Service may utilize connections to the Apple Health App (“HealthKit”),
Google Fit, Garmin Connect, and other third-party fitness, health, and tracking
applications and services (together with HealthKit, “Health Services”). For more
information on HealthKit, please click here. You can choose to connect and share
information with Health Services. If you grant access for us to write data to
Health Services, we can add information such as your activity recordings and
related information like activity distance, calories burned, active energy, and
flights climbed, amongst other data, to HealthKit.




Your unique health data you choose to send to Health Services Kit is not
accessible by AllTrails. Our Apps cannot write data to Health Services unless
you grant access. You can remove access at any time inside the Health Service.




Since we do not obtain or read any data from Health Services, such Health
Services data cannot be used by us for marketing or advertising purposes, or
shared with or sold to advertising platforms, data brokers, or information
resellers. Notwithstanding anything to the contrary in this Privacy Policy, the
use of information received from Google’s Health Connect will adhere to the
Health Connect Permissions Policy, including the Limited Use requirements.




AllTrails is in no way responsible for the protection of any of your information
that you agree to store with Health Services, which is governed by the privacy
policies and other terms of the applicable Health Service. You and the Health
Service are solely responsible for the protection of such information. Please
review the Health Service’s applicable policies and procedures before granting
permission to sync your health data and/or other information with the Health
Service.


LINKS TO OTHER WEBSITES

The Site and AllTrails Apps may contain advertisements for or links to other
websites, products, or services not operated or controlled by AllTrails,
including Social Media Sites (“Third Party Sites”). The information that you
share with Third Party Sites will be governed by the specific privacy policies
and terms of service of the Third Party Sites and not by this Privacy Policy. By
providing these links we do not imply that we endorse or have reviewed these
sites. Please contact the Third Party Sites directly for information on their
privacy practices and policies.

Our Approach to Privacy
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