Privacy Policy

Unbridled Privacy Policy

Last modified July 30, 2024

Introduction

Unbridled Solutions, LLC and its subsidiaries (herein, “Unbridled” or “We” or “Us”) respect your privacy, whether you are an Unbridled Client or Attendee. We are committed to protecting your privacy through our compliance with this policy. The use of information collected through our services shall be limited to the purpose of providing the service for which our Clients have engaged Unbridled.

This policy describes our practices in connection with information provided to us, or information collected during event registration or other related services (collectively, our “Services”).

This policy also applies to information about you that we collect or receive:

In e-mail and other electronic messages between you and Unbridled.
When you interact with an event website or service.

This policy does not apply to information collected by:

Any third party, including through any third-party application or content (including advertising) that may link to or be accessible from our Services.

Please read this policy carefully to understand our policies and practices regarding the collection of information about you, whether via our websites, applications, or from other sources, and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Services.

Privacy Classification

This policy classifies those using our Services as one of the following:

CLIENT: Entities or organizations that are Unbridled’s direct, contracted customers. Personally identifiable information of Client personnel associated with an event, meeting, or trip is treated as Attendee information, and will not be used for any purpose other than providing and supporting our Services (other than for limited exceptions described in the section below titled “How We Use Information” where applicable). Note that information relating to these same individuals who have visited and interacted with our marketing Websites (for instance, to download a white paper or sign up for an online demo) is treated as Visitor information.
ATTENDEE: Clients’ participants, or supporting personnel, which may include their employees, members, partners, or other third parties participating in Clients’ events, meetings, or trips (for example, individuals that register for an event organized by a Client, individuals whose information is provided to Unbridled by a Client, individuals who download an event-related mobile app, or who complete an online survey) are referred to as “Attendees.” Unbridled does not use personally identifiable information of Attendees for any purpose other than providing the Services contracted for by the Client (other than for limited exceptions described in the section below titled “How We Use Information” where applicable).

Information We Collect and How We Collect It

Unbridled, and our Clients that use our applications, sites, and/or Services to provide meetings and events, may collect several types of information from and about Attendees, including:

“Personally Identifiable Information” (PII) that identifies an Attendee as an individual or relates to an identifiable person. For example, this includes name, organization, job title, postal address, e-mail address, telephone number, fax number, social media account ID, or other identifiers by which Attendees may be contacted online or offline. This also may include information necessary for Attendees to utilize travel services from Unbridled such as date of birth, known traveler number, passport number, necessary travel accommodations, credit or debit card number, or other payment account number, as well as applicable expiration dates and billing addresses.
“Other Information” that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as information collected through cookies, pixel tags, and other technologies, general demographic information, and other information provided by a person, such as dietary preferences, travel preferences, interests, activities, age, gender, education, and occupation.

Unbridled may also collect Personally Identifiable Information and Other Information from Clients and Website Visitors. In some instances, we may combine Other Information with Personal Information. If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information.

We collect this information:

Directly from individuals when they provide it to us.
Directly from Clients when they provide it to us.
Automatically from Attendees, as they register for an event or meeting, arrange travel through Unbridled, use Unbridled’s applications, or from website visitors as they navigate through event Websites. Information collected automatically may include browser and device information, details regarding the use of the Services, IP addresses, and information collected through cookies, web beacons, and other technologies.

Information Provided to Us.

The information we collect through our Services may include:

Information that a person provides when utilizing one of our Services, for instance at the time an Attendee registers to attend a meeting being organized by a Client (Registration), submits a request for proposal (“RFP”), or downloads a mobile software application to the Attendee’s iPhone or Android device.
Information that Website Visitors provide by filling in forms on our Websites.
Information that Clients and Attendees provide when receiving customer or registration support. This includes records and copies of Client and Attendee correspondence (including email addresses).
Details of transactions Clients carry out through our applications, Event Registration Websites, and of the fulfillment of Client orders.

Anyone submitting Personal Information relating to other people to Unbridled in connection with the Services provided represents that they have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Use Information

We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:

To provide attendees with information, products, or services requested by our Clients using our applications, for example by processing event registrations, enrolling Attendees in programs in which they choose to participate, or providing Attendees with mobile application access for a meeting being organized for a Client.
To manage registration, travel, provide customer service, and process payments for purchases, travel, or accommodations for Attendees.
To provide Clients with updates or reports about their Attendees.
To notify Clients and Attendees about events, meetings, programs, or other updates related to the Services being provided.
To communicate with Clients and Attendees by email, postal mail, telephone, and/or mobile devices about Services.
For our business purposes, such as data analysis, audits, fraud monitoring, and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and operating and expanding our business activities.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; € to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
In any other way, we may describe when you provide the information.
To fulfill any other purpose for which you provide it or with your consent.

Disclosure of Your Information

We may disclose aggregated information about users and the use of our Services, and information that does not identify any individual, without restriction.

If you choose to use our Services to transact business with Clients (for example, register for an event, or download a mobile application), any information you provide in connection with that transaction will be transferred to, and under the control of, the Client. Although our own use and disclosure of your information will be in compliance with this Privacy Policy, Unbridled cannot and does not take responsibility for the privacy practices of Clients.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates for the purposes described in this Privacy Policy, including but not limited to providing Services to our Clients and to Attendees. Unbridled is the party responsible for the management of the jointly-used Personal Information.
To contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain, and support our Services, such as, for example, payment processors or Web hosting providers.
To fulfill the purpose for which information is provided, for example:
- If Attendees provide an e-mail address when registering for an event, we will use the email address to send the attendees information and announcements relating to that event.
- If Attendees utilize one of our Applications to pay for event registration fees or other products and services using their credit cards, we will pass the credit card information to payment card processors to validate the payment information and complete the transactions.
To enable processing of RFPs: When a Client or Attendee submits a request for proposal (“RFP”) to Unbridled, Unbridled will contact that Client or Attendee, potential venues, or other related third parties and disclose information necessary for it to respond to the RFP, which may contain Personal Information.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, our Clients, Attendees, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
For any other purpose disclosed by us when you provide the information or with your consent.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. The inclusion of any link provided to Clients and Attendees during the course of providing Services or within this Policy does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, BlackBerry, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers, or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the Applications.

Cookies and Similar Technologies

We and our partners may use cookies or similar technologies as you navigate through and interact with our Websites, our Applications, and third-party websites or other online services. We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Websites or Applications, such as the date and time you accessed our Websites, the length of time you spent on our Services, websites you visited before or after our Services, and the resources and content that you access and use on our Websites.
Information about your computer and internet connection, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, language, Internet browser type and version, and the name and version of the Services (such as the Application) you are using.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access or receive certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you direct your browser to our Websites or receive our Services.
Session Cookies and Persistent Cookies. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted. A persistent cookie will be reactivated when a user returns to the website that posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive. Cookies alone will not personally identify a user, however, a cookie may recognize a user’s web browser or device through an IP Address, browser version, operating system, and other information, and end users of our Services who log in to an Unbridled Website may be individually identifiable to particular Services using session cookies.
Flash Cookies. Certain features of our Services may use local storage, such as “Flash cookies” to collect and store information about your preferences and navigation to, from, and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices about How We Use and Disclose Your Information”.
Web Beacons. Pages on our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, single-pixel gifs, and tracking pixels). Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email messages. Web beacons permit us to track online movements of web users, for example, to count users who have visited those pages or opened an e-mail, and for other related website statistics, for example, recording the popularity of certain website content and verifying system and server integrity. This enables Unbridled to provide a website experience more tailored to your preferences and interests.

At this time, we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. You can learn about how you can adjust your browser’s settings to limit or disable cookies and other tracking technologies by visiting the section below titled “Choices About How We Use and Disclose Your Information.”

Choices About How We Use and Disclose Your Information

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:

Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, configure cookie notification settings and/or delete cookies already present on the browser or device. Information on how to do this should be provided in the web browser’s help/reference section. Visitors who block cookies may be able to access a Website but will not be able to use most of the content, applications, and services available on that site. Limiting or restricting certain types of cookies may also prevent a Client or Attendee from using certain portions of the Applications, depending on how the browser settings are configured. For example, event registration cannot be completed successfully if cookies are disabled in an Attendee’s web browser.

Data Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Information” section below.

Information Collected on behalf of our Clients

Unbridled collects information under the direction of its Clients, and has no direct relationship with the Attendees whose Personal Information it processes. If you are an Attendee of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you are affiliated with directly.

We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct queries to Unbridled’s Client (i.e., the data controller).

We will retain the Personal Information we process on behalf of our Clients for as long as needed to provide services to our Clients. Unbridled will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CCPA Privacy Policy

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information that we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA.

This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.
- Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, driver’s license number, passport number, or other similar identifiers.
- Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
- Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Collected: Yes.
Category D: Commercial information.
- Examples: Records and history of products or services purchased or considered.
- Collected: Yes.
Category E: Biometric information.
- Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Collected: No.
Category F: Internet or other similar network activity.
- Examples: Interaction with our Service or advertisement.
- Collected: Yes.
Category G: Geolocation data.
- Examples: Approximate physical location.
- Collected: No.
Category H: Sensory data.
- Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
- Collected: No.
Category I: Professional or employment-related information.
- Examples: Current or past job history or performance evaluations.
- Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
- Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Collected: No.
Category K: Inferences drawn from other personal information.
- Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
Indirectly from You. For example, from observing Your activity on our Service.
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.
To provide You with support and to respond to Your inquiries, including investigating and addressing Your concerns and monitoring and improving our Service.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. We do not sell personal information to any third party for compensation or any form of valuable consideration.

Share of Personal Information

We may share and may have shared in the last twelve (12) months the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers
Payment processors
Our affiliates
Our business partners
Third-party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not collect personal information from minors under the age of 16 unless they are included in an incentive program, in which case we collect first name, last name, and age. If we need to book flights for children under the age of 16, we also are required to collect the date of birth and gender. It is also possible that certain third-party websites that we link to may collect personal information. These third-party websites have their terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We know are less than 16 years of age.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes, and sharing of personal information.
- Once We receive and confirm Your request, We will disclose to You:
  - The categories of personal information We collected about You
  - The categories of sources for the personal information We collected about You
  - Our business or commercial purpose for collecting or selling that personal information
  - The categories of third parties with whom We share that personal information
  - The specific pieces of personal information We collected about You
- If we sell Your personal information or disclose Your personal information for a business purpose, We will disclose to You:
  - The categories of personal information categories sold
  - The categories of personal information categories disclosed
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions.
  - Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies.
  - We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    - Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    - Debug products to identify and repair errors that impair existing intended functionality.
    - Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if You previously provided informed consent.
    - Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    - Comply with a legal obligation.
    - Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  - The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
    - Denying goods or services to You
    - Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    - Providing a different level or quality of goods or services to You
    - Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By sending us an e-mail to: [email protected]
By sending us mail to:

Unbridled Solutions, LLC

ATTN: Data Protection Officer

1115 N Grant St

Denver, CO 80203

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

Verify Your identity or authority to make the request
And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this Website thirty (30) days prior to the changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: