PRIVACY NOTICE

Privacy Statement

Inhabit IQ and its family of software brands take pride in conducting business responsibly and ethically. We place the highest regard on the data privacy and security of our customers and on our legal obligations to protect such personal data.

iTrip LLC (“iTrip”, “we,” “us” or “our”), as an Inhabit IQ brand, developed a data privacy program that respects and protects the privacy rights of individuals whose personal information we process. We recognize that data privacy coincides with data protection, thus, we implement reasonable and appropriate data security and protection measures to preserve the confidentiality, integrity, and availability of the personal information we process. 

Contents

1. Who are we?
2. What is the scope of this Privacy Notice?

III. What do we collect?

1. How we use the personal information we collect     
2. Purpose for Processing
3. Interest-Based Advertising
4. Telephone Consumer Protection Act (“TCPA”) Notice
5. How we share and disclose your personal information     
6. How long we retain personal information

VII. How do we secure your personal information

VIII. Your Choices and Rights

1. Your Choices
2. Your Rights
3. California Privacy Rights
4. Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia
5. GDPR Privacy Rights
6. Exercising Your Rights
7. How to Exercise Your Rights
8. Use of an Authorized Agent
9. Minors
10. Changes to this Privacy Notice
11. Contact Us

Cookies

Your Privacy Choices

I. Who are we?

iTrip LLC, together with its subsidiaries and affiliates (“iTrip”, “we,” “us” or “our”), is a property management service provider operating under Inhabit IQ, a global PropTech software company serving the residential and vacation property management industries offering software-as-a-service (SaaS) solutions for core areas like accounting and operations, customer relations management, marketing, background screening, rent payment processing, and insurance.

iTrip provides property management and listing services with all the capabilities property owners need to manage their properties. Each iTrip location is owned and managed by a local iTrip Franchisee that receives corporate support from experts in software, technology, content, marketing, social media, SEO and more. Our Franchisees utilize proprietary systems and processes, receive support from a national leader in short-term rental management and provide boutique-level services which include: marketing, pricing, cleaning services and maintenance. When we use the term “Service(s)” we mean collectively:

1. The information provided through https://itripfranchise.com/, http://itripfranchise.com/, https://blog.itrip.net/, any other sites, applications and platforms owned and managed by us (the “Site(s)”);
2. The provision of online tools and platforms to those who avails of such tools and services; and
3. Our marketing and business development activities, including any social media properties we create, emails and text messages that we send (“Marketing”).

We offer these Services to Franchisees (property managers), Property Owners and Rental Guests. The Services are intended for a general audience and are not targeted to children under the age of 13.

We are a “Data Controller” under Data Privacy Laws for personal information processed as part of our operations including that of Franchisees, Franchisee Candidates, Property Owners, or Rental Guests in the performance of our Services.

Franchisees act as “Data Processors”, under Data Privacy Laws, processing personal information solely on our behalf and in accordance with iTrip’s instructions to provide localized property management services. A written agreement governs the relationship, ensuring Franchisees comply with their obligations as Data Processors.

II. What is the scope of this Privacy Notice?

We strive to be transparent and keep you informed on how we process your personal information through this notice. This notice sets out how we collect, use, store, share, dispose, and protect your personal information as a Data Controller. Franchisees, acting as Data Processors, process your personal information strictly under our instructions as outlined in this notice and applicable agreements. 

This Privacy Notice covers the disclosures that are required by “Data Privacy Laws” governing our processing of personal and sensitive personal information, which include, but are not limited to the following: 

• The General Data Protection Regulation and the UK Data Protection Act 2018 and General Data Protection Regulation;
• Canada’s Personal Information Protection and Electronic Documents Act, Alberta and British Columbia's Personal Information Protection Act (PIPA), Quebec's Law 25 (Private Sector Act); and
• US state privacy laws currently in effect—including the California Consumer Privacy Act, the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Delaware Personal Data Privacy Act, the Florida Digital Bill of Rights, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, New Hampshire Senate Bill 255, New Jersey Senate Bill 332, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act of 2022, and the Virginia Consumer Data Protection Act of 2021—as well as similar state laws such as  Indiana Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, to the extent they take effect.

This notice applies as we process personal data as a Data Controller relating to:

• visitors to iTrip Site(s);
• our Franchisees including their representatives, officers, employees, partners, independent contractors, agents and other authorized internal users; 
• our Franchisee Candidates including their representatives, officers, employees; 
• Property Owners and their representatives; and 
• Rental Guests.

If you are an individual Rental Guest or a Property Owner of a property managed by a Franchisee who has been invited to use the client-facing features of the Services in a limited capacity, the Franchisee will process your personal information in accordance with iTrip’s instructions and guidelines.

This Privacy Notice does not cover the practices of companies we do not own or control or people we do not manage and this Privacy Notice does not apply to any third-party sites that may link to or be accessible from our Sites.

We use some phrases in this Privacy Notice that are unique to our business or our Services. Below are definitions of some of the key terms:

• “Personal Information or Personal Data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include anonymized, de-identified or aggregated information, certain information publicly available, or certain other information excluded from the scope of various Data Privacy Laws.
• “Sensitive Personal Information” varies depending on the applicable Data Privacy Laws. Generally, this includes information that could harm an individual if disclosed, this requires a higher level of security and protection and is subject to additional restrictions and regulations. It includes health, financial, biometric data, genetic data and other identifying information. 

• “Processing” means any operations performed on personal information, including: collecting, storing, retrieving, consulting, analyzing, disclosing or sharing with someone else, erasing, or destroying personal data.

• “Franchisee” refers to the property managers who we contract with and provide our Services for under a Franchisee Agreement.

• “Rental Guest” refers to the individual Rental Guest of a property managed by a Franchisee who has been invited to use the client-facing features of the Services in a limited capacity whose personal information are processed by the Franchisee on behalf of or upon the instructions of iTrip. 

• “Property Owner” refers to individuals who own properties managed by the Franchisees.

• “User” refers to individuals who are given access to the platforms we offer as part of our Services. They can be Primary Users: representatives, officers, employees, partners, independent contractors, agents and other authorized internal users of our Franchisees or Secondary Users: the Property Owners or Rental Guests of our Franchisees.

III. What do we collect?

We collect the following Personal Information directly from you or through Franchisees. All data processed by Franchisees is collected on behalf of iTrip and remains under iTrip’s control.

• Data of our Franchisees, Franchisee Candidates, Property Owners, Potential Property Owners, Users and Site Visitors

1. Directly from you when you interact with our customer support by email, regular mail or telephone; or when you use any of our applications as Franchisees or its Primary User:

• Name, phone number, email address, property address or unique personal identifiers (wireless device ID, cookies, IP address) (“Identifiers”).
• Occupation, position or designation (“Demographic Data”)
• Commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
• Usernames, passwords, log-in credentials (“Log-in Data”)
• Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”).

1. Directly from you as a visitor to one of our Site:

When you visit our Site, you may choose to provide information to us, such as when you contact us to request or provide information through the our data collection tools in the Site such as in “Start Your Franchise Journey”, “Franchisee Opportunity”, “Contact Us”, “Resource Library”, “List Your Property”, subscription, sign-up and log-in pages on the Sites.

In addition, when you interact with our Sites, we use technology and Google tools (such as Google Analytics, Google AdSense, Google Display Network Impression Reporting) to gather information on how visitors are using the Sites and Services. For more information, see Google’s explanation at “How Google uses information from sites or apps that use our services.”

We collect IP address information so that we can properly manage our system and gather information about how our site is being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Information. We collect details of visits to our Site, including the volume of traffic received, logs and the resources that you have accessed. 

We may collect the following categories of information from our Sites:

• Name, phone number, email address, state, property address, unique personal identifiers (cookies, IP address), (“Identifiers”).
• Usernames, passwords, log-in credentials (“Log-in Data”).
• Internet or other network or device activity (such as type of device, internet connection, browser type and version, time zone, operating system and platform, referring/exit pages, account access date/time stamp, UTMs (Urchin tracking modules) for lead source) (“Internet Data”).

1. From our Franchisees as needed for us to perform our Services for them.

• Name, phone number, email address, and any other information necessary to complete applicable documents or applications provided (“Identifiers”).

• Data of Rental Guests

1. Directly from you as a Rental Guests who has been invited to use the customer-facing features of the Services in a limited capacity or via your booking activities:

• Name, phone number, email address, birthday, unique personal identifiers (IP address) (“Identifiers”).
• Financial information (such as credit or debit card information, verification number, and expiration date), bank account number (“Financial Data”).
• Usernames, passwords, log-in credentials (“Log-in Data”)
• Internet or other network or device activity (such as browser type and language, operating system or app usage) (“Internet Data”).

1. From our Franchisees, service providers and business partners as needed for us to perform our Services.

• Name, phone number, email address, unique personal identifiers, passport number (wireless device ID, cookies, IP address), (“Identifiers”).
• Financial information (such as credit or debit card information, verification number, and expiration date), bank account number (“Financial Data”).
• Internet or other network or device activity (such as browser type and language, operating system or app usage) (“Internet Data”).

IV. How we use the personal information we collect     

• Purpose for Processing

We only collect the information reasonably necessary to provide our Services, to carry out our operations, as required by law, and for the other legitimate business purposes, under applicable laws.

Some of these uses may, under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to our Franchisees, or are necessary to serve our legitimate interests as provided below:

1.  For provision of our Services:

• To facilitate the use of the software application, to maintain and administer Franchisees’ account which includes sending transaction records, notice and other documents necessary for the continued use of the application and for other purposes that would be necessary or beneficial to administer our Franchisees’ use of the same (“Servicing”).
• To continuously provide you with our services through your use of the platform and access of its database (“Servicing”).
• To respond to your queries, comments, feedback, or requests and address your complaints and provide customer support (“Servicing”).
• To verify or ascertain your identity, uniquely identify you or your business and identify potentially fraudulent activity (“Fraud Prevention”).
• To carry out our obligations arising from of our contracts with our Franchisees (“Servicing”). 
• To conduct research and gain an understanding of the users of our platform, their experiences and preferences to further improve the platform (“Quality Improvement”).
• To assist in business development, compile statistics regarding how the Site or our Service is used in order to improve them, for example, we may use your personal data to improve the layout of our Site based on the click path you utilized to access certain information within the Site (“Quality Improvement”).
• To detect or prevent security incidents or other illegal activity, debug, verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us (“Security”).

1. For marketing and advertising activities (“Marketing”):

• To communicate with you regarding services, activities, programs, trainings, promotions, services, products or other offers in which you have indicated an interest or to which they’ve subscribed and to contact you with information that may be of interest to you.
• To provide you newsletters, articles, alerts and announcements and other information we think they may find useful or which you have requested from us.
• To personalize your experience and allow us to deliver individualized content and product offerings according to your specific interests.
• To provide you with marketing materials of third parties which we think may interest you. 

We only process the personal data of Rental Guests or Property Owners for our own marketing purposes in compliance with applicable laws. 

We do not sell or share text messaging originator opt-in data and consent status with any third parties for marketing or promotional purposes.

1. For compliance with our legal obligations, regulatory requirements and for other legal purposes (“Legal”):

• To process any complaints, implement preventive measures and to investigate act, omission, or misconduct that would constitute a violation of our contracts and of the applicable laws. 
• To verify your identity or conduct internal audits or reviews.
• To enforce our Franchise Disclosure Document (FDD) and Franchise Agreement (FA) and other applicable agreements.
• To gather the necessary information required by law, record keeping and good business practices.
• To comply with our legal obligations and other regulatory requirements.
• To protect our lawful rights and interests in court proceedings and to establish, exercise or as defense from legal claims.

B. Interest-Based Advertising

We and our third-party advertising partners may use cookies or web beacons to collect information for the purposes of interest-based advertising based on your visits to our Site. These cookies identify the pages you view, the links and ads you click on, other actions you take on those websites, and the referring website. Similarly, online advertisers use cookies to deliver advertising to you for companies other than us based on your visits to our Site and other websites. To know more read our Cookie Policy. 

C. Telephone Consumer Protection Act (“TCPA”) Notice

With your consent or based on our past transactions, you may receive calls, emails, or SMS messages from us for marketing and service updates related to our agreement or your account. We will only send you relevant information that interests you.

We might use any contact method you provide, including text messages, recorded calls, or automated systems. If an agent calls, they may leave a message if you are unavailable.

We may record calls for quality monitoring and will inform you of any charges from your mobile provider. 

These communications will only occur with your consent or as a result of our previous interactions. You can opt-out of marketing messages by following the instructions in the messages we send.

V. How we share and disclose your personal information     

The below chart summarizes the categories of personal and sensitive personal information we collect, from where we collect it, how we use it, and with whom we share it.

This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review in compliance with the CCPA.

We generally do not directly sell your Personal Information in the conventional sense (for money). Like many companies, however, we do disclose Personal Information for internal business purposes or operational purposes of our business (servicing, quality improvement, fraud detection, security, legal), and we use services that help deliver interest-based ads to you or analyze our website traffic. Making personal information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under certain Data Privacy Laws. If you would like to opt out of sales of your personal information that take place via cookies, immediately notify us in accordance with the “Your Choices and Rights” section below.

We share Personal Information with the following categories of recipients for the following business purposes:

1. Third-party Service Providers: Your Personal Information will only be shared with and processed by our affiliates and non-affiliated third-party service providers as permitted by law and for the purposes described in this Privacy Notice.  We may disclose Personal Information to certain non-affiliated specialized service providers, including professional advisors, consultants, technical service providers, and other third parties, who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  We may disclose your Personal Information to third-party service providers to provide us with services such as Site hosting, including information technology and telephony services, and related infrastructure, customer service, e-mail delivery, auditing, and other similar services.

1. Corporate Subsidiaries and Affiliates: We share the collected personal information as described in this notice with our subsidiaries and affiliated businesses within the Inhabit IQ, each of which use your personal information consistent with this Privacy Notice.  Those businesses may also use your personal information for each of their own purposes, including marketing purposes. Please visit their Privacy Notice on their website to learn more.

1. Business Transfers: When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

1. With Your Consent or at Your Direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

1. Other Legal Reasons: In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from public and government authorities including public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect our rights, privacy, safety or property of, our affiliates, you and others; and (7) to enforce our terms and conditions.

When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.

VI. How long we retain personal information

We will retain your Personal Information for as long as your account is active, for the period necessary to fulfill the purposes outlined in this Privacy Notice, to perform our obligations and provide you our Services. We will also retain your information to comply with our legal obligations, to conduct audits, resolve disputes, and enforce our agreements.

Franchisees are required to follow iTrip’s data retention policies and delete or return all personal data upon instruction from iTrip. Franchisees must not retain personal data beyond the duration specified by iTrip or applicable law.

VII. How do we secure your personal information

We use reasonable organizational, technical and physical measures to maintain the privacy and security of your Personal Information within our organization against any unauthorized access, use, disclosure, loss or alteration, or theft of personal information. We maintain policies and practices to ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
• Technical safeguards such as encryption, firewalls, antivirus software and similar measures to protect information stored in electronic format;
• A designated Privacy Officer to monitor our compliance with applicable privacy laws;
• Employee privacy and data security training; and
• Procedures for receiving, investigating and responding to security incidents involving personal information.

Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. 

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below. 

VIII. Your Choices and Rights

We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.  

If you are a Rental Guest or a Property Owner of a property managed by iTrip, you may exercise your choices and rights directly with iTrip as the Data Controller. Franchisees, acting as Data Processors, facilitate such requests in accordance with our instructions.

A. Your Choices

To ask us to remove your information from our marketing mailing lists, please contact us as outlined in the How to Exercise Your Rights Section below.  You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.  Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to our Services, such as service announcements.

B. Your Rights

Subject to applicable Data Privacy Law, you may have certain rights to know, access, update, port your personal data, correct inaccuracies, delete, restrict processing of your personal information in our custody and control.

For security purposes, we will verify your identity when you request to exercise your data privacy rights.  For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate.  

You right over your personal information depends on the Data Privacy Law applicable where you reside:

• California Privacy Rights

For additional information for residents of the State of California click here.

The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA and CPRA.  The CCPA and CPRA shall be collectively referred to herein as the “CPRA”.

Additional Disclosures

• Do-Not-Track Disclosure

“Do Not Track” (“DNT”) is the concept that has been promoted by regulatory authorities for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Currently, various web browsers (Chrome, Firefox, Safari, Internet Explorer, Microsoft Edge) offer a DNT option that sends a signal to websites visited by the browser user about the user’s DNT preference. We do not recognize or respond to browser initiated Do Not Track (DNT) signals as a DNT standard has not been adopted to this day.

Our third-party partners, such as web analytics companies and third-party ad networks, may collect information about you and your online activities over time and across our Services and our Site. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

Your Rights

As a California Consumer, you have the following rights, these rights are not absolute and may be subject to exceptions and verification.  We may be required or permitted by law to decline any request.  Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your personal information.

• Right to Know, Access, Data Portability 

You have the right to know the categories and specific pieces of personal information that we collect about you, the purposes of the collection of your personal information, categories of third parties with whom we share your personal information and the categories of the personal information that we shared with third parties.

You can also make a request to access the categories or specific pieces of personal and sensitive personal information we collected, used, or shared about you in the past twelve (12) months.  Along with your verified request, we will give you any categories of sources from which the personal or sensitive personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information. 

• Right to Delete

You can make a request to delete any personal and sensitive personal information we collected from you. Upon receiving a verified request, we will notify you once your information has been deleted. We will also communicate your deletion request to the third parties who process your personal information on our behalf and direct them to delete your information.

• Right to Opt-Out of Sale

California Consumers have the right to opt out of “sales” of their personal information.

The CCPA’s broad definition of  “sale” may include using services to deliver targeted advertising on other sites or applications. This means that if you make a request to opt out of our “sales” of personal information, it will likely have a direct impact on the types of advertisements you see online. We will honor requests to opt out of “sales” of your personal information. 

If you would like to opt out, you may do so as outlined on the following page: You Privacy Choices

You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

We do not knowingly “sell” or “share” the personal information of people under 16 years old.

1. Right to Limit the Use or Disclosure of Sensitive Personal Information

We only use your sensitive personal information for business purposes or operational purposes of our business (servicing, quality improvement, fraud detection, security, legal), thus, your sensitive personal information is processed to only that which is essential for providing you our services, providing services to our Clients and for other legitimate business purposes. 

We will notify you if at any point we intend to use your sensitive personal information for any additional purposes.

•      Right to Non-Discrimination

We value giving consumers control over their privacy and personal information.  If you choose to exercise any of your rights under the CCPA, we will not differentiate our services as a result of your decision.  We also do not offer any financial incentives to opt-in to sell your personal information.

• Right to Correct

You have the right to request the correction, updating and completion of any Personal and Sensitive Personal Information we maintain about you.

• Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia

For additional information for residents of any of these states click here.

Your Rights

The U.S. privacy laws provide their consumers with specific rights regarding their personal information. To the extent that you are a resident of one of these states, this section describes your rights under the applicable Data Privacy Laws and explains how you may exercise these rights.

The categories of personal information we process, our purposes for processing, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are detailed in Section 4.To the extent that our personal information processing activities are addressed by a separate privacy notice, please consult the terms of that privacy notice for detailed information about our data practices, including the categories of personal information that we collect and disclose.

• Right to Know

You have the right to know whether we process your personal information.

• Right to Access

You can make a request to access the categories or specific pieces of personal and sensitive personal information we collected, used, or shared about you.  Along with your verified request, we will give you any categories of sources from which the personal or sensitive personal information is collected; the purpose for collecting, selling, or sharing; and any categories of third parties with whom we share such personal information. 

• Right to Data Portability

You have the right to access and obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such personal information up to twice annually, subject to certain exceptions.

• Right to Delete

You have the right to delete personal information that you have provided by or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception to this right set forth in Data Privacy Laws. If the personal data is no longer needed for any purposes that justify its retention and we are no required by law to retain it, we will do what we can to delete. We may need certain types of data so that we can provide our Services to you.  If you ask us to delete it, you may no longer be able to access or use our Services. 

1. Right to Opt Out of Selling or Sharing

You have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (provision or denial of housing, insurance, employment opportunities, or access to essential goods or services; decisions that have a foreseeable risk of unfair or unlawful treatment, financial or physical injury or other substantial injury).

As of the latest date of the Privacy Notice:

• We DO process personal information for the purposes of targeted advertising.
• We generally DO NOT directly sell your personal information in the conventional sense (for money). Like many companies, however, we do disclose personal information for internal business purposes or operational purposes of our business (servicing, quality improvement, fraud detection, security, legal, auditing, and service improvement), and we use services that help deliver interest-based ads to you or analyze our website traffic. Making personal information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under certain Data Privacy Laws. 
• We DO NOT engage in profiling decision based on your personal information that produce legal or similarly significant effects concerning you.

If you would like to opt out of “selling” or “targeted advertising”, you may do so as outlined on the following page: You Privacy Choices

You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

• Right to Correct

You have the right to correct inaccuracies in the personal information we collect from you, taking into account the nature of the personal information and the purposes for which we process it.

• Right to Nondiscrimination

We value giving consumers control over their privacy and personal information.  If you choose to exercise any of your data privacy rights, we will not differentiate our services as a result of your decision.  We also do not offer any financial incentives to opt-in to sell your personal information.

• Your Right to Appeal

Under applicable Data Privacy Laws, if we decline to take action or do not respond regarding a request that you have submitted pursuant to one of the privacy rights set forth in this section, you have the right to appeal our refusal to take action within a thirty (30) calendar days after you receive our decision. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general’s office to submit a complaint.

• GDPR Privacy Rights

For additional information for residents of United Kingdom, Switzerland, and other European countries click here.

If you are a resident of one of many European countries, including the United Kingdom and Switzerland, an important European privacy law (or an equivalent counterpart to it) the General Data Privacy Regulation (the “GDPR”) provides you with certain rights, and places certain obligations on companies regarding how your “personal data” (as the GDPR uses that term) is used.  We describe those rights and obligations below, and how and in what circumstances we honor them.  

We set out our compliance with the GDPR and, to the extent applicable, those other laws, in this section.

Legal Basis

The GDPR requires us to tell you about the legal ground we’re relying on to process any personal data about you. The legal grounds for us processing your personal data for the purposes set out in Section IV above will typically be because:

• You provided your (legally sufficient) consent;
• It is necessary for our contractual relationship, e.g., in order to provide you services or features you’ve requested and we’ve promised;
• The processing is necessary for us to comply with our legal or regulatory obligations – for instance, to communicate with you about or to help honor your legal rights; and/or
• The processing is in our legitimate interest.   For instance, we may process and share business data collected from our website for our own internal marketing purposes, or other information for purposes of security, data hygiene or validation, in a manner that constitutes a “legitimate interest”.

Your Rights

• Right to Rectify, Delete, Restrict or Object to the Processing

Your rights to deletion or revocation of consent (sometimes referred to as a right to be forgotten, to restrict processing, or to otherwise object to processing).  You have the right to request that we delete your personal data (or where applicable, withdraw your prior consent to our processing of your data).  You may also request that we correct or rectify your personal data if it is inaccurate, incomplete or false.

If you request that we delete your personal data, or withdraw your consent, we will customarily retain a copy of your data sufficient to suppress it from our active databases in the future:  but if that is not what you wish, you may indicate that to us (in which case your information may be added to our database later, because we will not have “suppressed” it).

Moreover, when we delete your personal data, we may retain it (to the extent legally permissible) for certain important (but narrow) internal purposes such as legal, compliance, accounting or auditing purposes, and in some cases, for security purposes.  

• Personalized Online Advertising Opt-Outs

You may object to profiling by online advertising platforms with whom we sometimes partner to help generate (and measure or analyze) “personalized” online advertising.  These platforms are generally separate third party “controllers” of your data.  

You may unsubscribe from marketing and other communications that we may send (on behalf of ourselves or others) by clicking the “opt-out” or “unsubscribe” link in the footer of those emails. 

• Your Right to Access 

In some jurisdictions, you may have the right to request access to a copy of your personal data.  When you request access to your personal data, we are required — for privacy and other important compliance reasons — to verify your identity in a legally sufficient manner: if we cannot do so, we will not be able to satisfy your access request.

Please note that as part of the verification process, we may not be able to sufficiently “verify” your identity in a manner sufficient to safeguard against the potential adverse privacy effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another).  Because such improper disclosure would likely adversely affect the privacy rights and freedoms of a relevant data subject/consumer, we limit certain personal data we make available.  

• Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe your data rights have been violated. In particular, if you are an individual in the European Union, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work or of an alleged violation of data protection laws.

Questions or Concerns

If you have a complaint or concern or question about how we handle your personal data, please contact us as at the above contact addresses, and we will seek to address any concerns you may have.  If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

C. Exercising Your Rights

This provides for instructions on how you can exercise your rights under applicable Data Privacy Laws.

1. How to Exercise Your Rights

To submit a request to access, rectify, delete, port your personal data you can submit a request to us by email at privacy@itrip.net.

Note in the body of the email the specific right you want to exercise. In the subject line, include “<Your State/Country> Consumer Request”.

To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request.  Your request must include details sufficient for us to properly understand, evaluate, and respond to the request.   

Please also note that as part of the verification process, we’re required to consider:

• the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with; and
• the potential adverse effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another) because such improper disclosure would likely adversely affect the privacy rights and freedoms of the relevant data subject/consumer, we limit certain personal data we make available.  

2. Use of an Authorized Agent

An agent legally authorized to act on your behalf—may make a verifiable request related to your personal information. If you are making a request through an authorized agent, you must provide the authorized agent with written permission to do so, and a power of attorney that fulfills the requirements of the Data Privacy Laws. We may request more information from the authorized agent (or from you) if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.

3. Minors

We do not knowingly collect personal information of minors (minority age depends on the applicable Privacy Laws) under the age of 13, nor are our Sites or Services developed for, offered to, or directed at children under the age of 13. If you believe that we have collected information of a child under the age of 13, please contact us and we will take appropriate action. 

IX. Changes to this Privacy Notice

Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on our Site or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

X. Contact Us

If you have any questions, or complaints, regarding the collection or use of your personal information or the content of this notice, please contact our Privacy Officer at the coordinates below. 

Privacy Officer

Inhabit
2035 Lakeside Centre Way, Suite 250, Knoxville, Tn 37922

privacy@itrip.net

We respect your privacy rights and commit to the security of your personal information. If you do not agree to how we process your personal information as discussed in this Privacy Notice, please reach out to us. Please also see the appropriate service agreement for more information on the Services we provide.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and Services. For a complete list and more information about our use of cookies, please read our Cookie Policy.

Cookie Policy

Effective as of 05/14/2026

This Cookie Policy (“Policy”) explains how iTrip LLC (“iTrip”, “we,” “us” or “our”) use cookies and similar tracking technologies on our websites, applications, and other digital platforms (collectively, the “Services”). It also explains your rights and choices regarding these technologies, and forms part of the iTrip Privacy Policy.

By using our Services, you agree to our use of cookies in accordance with this policy. If you do not agree, you may disable cookies through your browser settings or other means described below.

• WHAT COOKIES WE COLLECT

Cookies are small text files placed on your device when you visit a website. They help us recognize your device, improve your browsing experience, and analyze how our Services are used. Other tracking technologies, such as pixels and local storage, may also be used and function similarly to cookies.

Cookies can be classified based on various factors such as their duration, purpose, and origin. These classifications help differentiate how cookies function and the role they play in a user’s browsing experience.

• By Lifespan

• Session Cookies: These are temporary cookies that expire once you close your browser. They are used to maintain session integrity, such as keeping you logged in while navigating a website.
• Persistent Cookies: These remain on your device for a predefined period, even after you close your browser. They help remember your preferences and login details for future visits.
• By Purpose
• • Necessary Cookies: These are essential for the website to function correctly. They enable core features such as page navigation, security, and accessibility. Because they are required for the website to operate, they are automatically stored on your browser.

• Functional Cookies: These cookies improve website functionality and provide a more personalized experience. They help remember your preferences, such as language settings, display options, and login details, so you don’t have to re-enter them each time you visit.

• Analytics Cookies: Analytics cookies help us understand how visitors interact with the website by collecting anonymous data about page views, time spent on the site, and navigation patterns. This information allows us to improve performance, optimize content, and enhance the overall user experience.

• Advertisement Cookies: These cookies are used to deliver ads that are more relevant to you. They track your browsing habits across websites to provide personalized advertisements and measure the effectiveness of marketing campaigns. They may also be set by third-party advertising partners.
• Performance Cookies: These cookies are used to understand and analyze the key performance indexes of the website which helps in delivering better user experience for the visitors.
• By Origin
• First-Party Cookies: These are cookies set by the website or service you are visiting.

• Third-Party Cookies: These are cookies set by external domains (e.g. advertisers or analytics providers). 

We use and govern cookies on our websites. You may check the description of the cookies we use, their purpose and duration and may exercise your right to opt out through our Cookie Consent Preference Banner.

• HOW WE USE COOKIES

When you interact with the our website, applications, emails, or advertisements, we (and third parties) may automatically collect technical information from your browser or device using cookies, pixels, web beacons, local storage, JavaScript, APIs, and similar technologies.

We use these technologies to:

• Personalize your experience and remember your preferences
• Analyze website traffic and user behavior
• Improve the performance and security of our services
• Deliver and measure targeted advertisements
• Prevent fraud and ensure system security

Additionally, we may use clear GIFs (also known as web beacons or pixel tags), which function like cookies but are embedded in web pages and emails. These help us track user engagement, manage content, and measure email performance, such as open and forward rates.

• WHAT COOKIES DO WE COLLECT ON OUR WEBSITE AND WHAT ARE THEY USED FOR

We use and govern the following cookies on our websites:

• HOW TO MANAGE COOKIES

You can control or disable cookies through the following methods:

• Browser Settings

Most browsers allow you to block or delete cookies through their settings. Refer to your browser’s help section for instructions:

• Chrome: Google Support
• Firefox: Mozilla Support
• Safari: Apple Support
• Edge: Microsoft Support

• Opt-Out Tools

To disable certain analytics cookies, you can use the browser controls discussed above or, for some of our providers, you can use their individual opt-out mechanisms, such as the Google Analytics Opt-Out.

• Disabling cookies via the Cookie Banner

To customize your cookie preferences on this website, please click on the Cookie Banner. In the Cookie Banner, you will find information about the cookies being collected, and you can choose whether or not to accept their use, except for those that are strictly necessary for the website’s operation.

Note: Disabling cookies may affect your experience on our website.

• DO-NOT-TRACK

We do not recognize or respond to browser-initiated DO-NOT-TRACK (DNT) signals, as a DNT standard has not been adopted to this day. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

• CHANGES TO THIS COOKIE POLICY

We may update this Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be posted on our website with a revised effective date.

Your Privacy Choices 

Your Right to Opt-out of Sale

Under applicable Data Privacy Laws, you have the right to opt out of “sales” of your personal information.

Data Privacy Laws broadly define sale such that it may include allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising. This means that if you make a request to opt out of our “sales” of personal information, it will likely have a direct impact on the types of advertisements you see online. 

How to Exercise Your Right

You have the right to opt out of the sharing and selling of your personal information by clicking on the Do Not Sell/Share My Personal Information link on the banner below. 

You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

When you enable your preferences via GPC and it is recognized by a website, you will automatically be opted out of targeted advertising and any activities that involve the sale or sharing of their personal data.