Welcome to TROOP, a centralized data platform that helps organizations plan the most effective in-person meetings and event strategies, operated by Troop Travel, Inc., a Delaware corporation with offices located at 251 Little Falls Drive, Wilmington, DE 19808 (“TROOP”, “Troop Travel Inc.”, “Company”, “we”, “us”, or “our”). Your privacy is very important to us, and in order to protect your information, we have adopted this privacy policy (“Privacy Policy”). This Privacy Policy describes the types of information we collect from registered or unregistered end users (each, a “User”, “you”, or “your”) of our websites, https://www.trooptravel.com/, https://app.trooptravel.com/ (the “Sites”), and any TROOP applications (the “App”, and collectively with the Site and all services provided therein, the “Platform”), how such information is used, processed and, in certain cases, disclosed by us, and your rights and choices regarding the information you provide to us. Please read this Privacy Policy carefully prior to your use or creation of a registered User account (an “Account”) on the Platform. If you do not agree to this Privacy Policy, please do not use our Platform or create an Account.

By accessing and using the Platform or creating an Account, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use, and disclosure practices described herein. This Privacy Policy is governed by the Terms of Use, which includes all disclaimers of warranties and limitations of liabilities. Capitalized terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Use and the below regulations.

We adopt this Privacy Policy to comply with all relevant and applicable state, federal, and foreign privacy laws and regulations, including, but not limited to the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), the General Data Protection Regulation (“GDPR”), and the UK GDPR (collectively, the “Regulations”).

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Collected: Yes

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

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

Commercial information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected: Yes

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: Yes

Internet or other similar network activity

Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Collected: Yes

Geolocation data

Examples: Physical location or movements.

Collected: Yes

Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No

Professional or employment-related information

Examples: Current or past job history or performance evaluation.

Collected: No

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

Inferences drawn from other personal information

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes

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

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Platform.
We will also collect information about you from third parties, for example, third-party travel services, your employer (if you are accessing the Services as part of your job), or other users who may invite you to use the Services.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

Identify you and potentially improve and/or customize the Platform
Send you administrative notices or Account notifications
Send you requested service and other Platform information
Address inquiries and respond to customer service requests, questions and comments
Administer your Account and manage your Account profile information
Send you newsletters and mail (including email)
Contact you with offers, promotions and other product specials
Send you more relevant marketing communications and general Platform information/updates
Create a more personalized User experience and customize certain content you see on the Platform
Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings
Improve your user experience and increase the efficiency and effectiveness of the Platform service and functionality offerings
Maintain security
Enforce our Terms of Use and applicable law
Analyze Platform usage and other trend data
Solicit feedback, reviews, and other information regarding your experience with the Platform
Test new features, service offerings and functionalities on the Platform
To connect to certain SM Channels and other third-party services that integrate with the Platform
Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection
For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services.
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 Regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We do not sell personal information. In the preceding twelve (12) months, TROOP has not sold any categories of personal information.

Identifiers

Business Purpose Disclosures: Data Analytics Providers; Operating Systems & Platforms; Service Providers; Partners

Sales: None

Personal information categories listed in the California Customer Records statute

Business Purpose Disclosures: Data Analytics Providers; Operating Systems & Platforms; Service Providers; Partners

Sales: None

Protected classification characteristics under California or federal law

Business Purpose Disclosures: None | Sales: None

Commercial information

Business Purpose Disclosures: Service Providers; Partners | Sales: None

Biometric information

Business Purpose Disclosures: None | Sales: None

Internet or other similar network activity

Business Purpose Disclosures: Data Analytics Providers; Operating Systems & Platforms; Social Networks | Sales: None

Geolocation data

Business Purpose Disclosures: Data Analytics Providers; Operating Systems & Platforms | Sales: None

Sensory data

Business Purpose Disclosures: None | Sales: None

Professional or employment-related information

Business Purpose Disclosures: Regulatory Entities | Sales: None

Non-public education information

Business Purpose Disclosures: None | Sales: None

Inferences drawn from other personal information

Business Purpose Disclosures: Data Analytics Providers, Service Providers, Partners | Sales: None

Social Media Plug-Ins

We may use the following social media plug-ins: Facebook, WhatsApp, Instagram, Twitter, LinkedIn, Apple iMessage, and may in the future use others. This allows you to communicate with such service and “like” or “comment” on the Platform. The social media plug-in enables a direct communication between your end-user device and the servers of the social media provider, allowing the social media provider to communicate with you and collect information about you browsing our Platform. When you use a social media plug-in, transfer of your personal information may take place whether you have a registered user account with the applicable social media provider or not. We are not responsible for the content and data collection on respective third-party websites or apps. For further information as to how the social network provider processes your data, please see their relevant privacy policies.

Information that May be Publicly Accessible

Certain personal information that you upload to the Platform (such as certain Account profile information), certain User Content, and certain Platform usage information will automatically, or upon your selection, be made publicly available to other Users on the Platform. You acknowledge and agree that certain Account information that you provide in connection with the registration of your Account and your general use of the Platform will be publicly viewable by all Users of the Platform. We are not responsible for the privacy practices of the other Users who will view and use this information. You should not disclose your home address or the address of your place of business in any User Content.

Account Registration

The Platform allows you to create an Account via certain Media Login Channels. By using this functionality, you give us permission to access certain elements of your Media Login Channel account profile information that you have made available to be shared, and to use it in accordance with the applicable Media Login Channel’s terms of use and this Privacy Policy.

TROOP does not retain your username or password for Media Login Channels for any longer than is necessary to complete an interaction. If you would like to disconnect a Media Login Channel user account from the Platform, refer to the settings of that social media account and its provider.

Storage and Transfer of Information

Information collected by us may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence. We will endeavor to take reasonable measures to maintain an adequate level of data protection when sharing your personal information with such countries.

We strive to keep our processing activities with respect to your personal information as limited as possible. We will retain the information we collect from or about you only as long as necessary to provide you with the Platform or our services, and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect our legal rights. We may retain indefinitely any aggregated, anonymized, or pseudonymized information.

With respect to any personal information originally collected and stored in the EEA, if and when we transfer your personal information to countries outside the EEA, we will do so under the Commission’s Standard Contractual Clauses. For a copy of these Standard Contractual Clauses, please contact us at privacy@trooptravel.com.

Your Rights and Choices

The Regulations provide individuals with specific rights regarding their personal information. As an overview, you may have the following rights under the Regulations:

The right to require free of charge (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
The right to request proper rectification, removal or restriction of your personal information;
Where processing of your personal information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal information in a structured, commonly used and machine-readable format, or to have your personal information transmitted directly to another company, where technically feasible (data portability);
Where the processing of your personal information is based on your consent, the right to withdraw your consent at any time;
The right not to be subject to any automatic individual decisions which produce legal effects on you or similarly significantly affect you; and
The right to take legal actions in relation to any breach of your rights regarding the processing of personal information, as well as to lodge complaints before the competent data protection regulators.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity, 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 that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales and disclosures for a business purpose.
The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary to:

Complete the transaction for which we collected the personal information or otherwise perform our contract with you.
Detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech or ensure the right of another consumer to exercise their free speech rights.
Comply with the California Electronic Communications Privacy Act or the Regulations.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.
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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Right to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at privacy@trooptravel.com. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a twelve (12)-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include verifying your name, account information, or other relevant details, or by logging into your password-protected account.
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 personal information if we cannot verify your identity or authority to make the request. You do not need to create an account with us to submit a request to know or delete.

Response Timing and Format

We will confirm receipt of your request within seven (7) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age sixteen (16) or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). However, TROOP does not sell your personal information, including the personal information of consumers we actually know are less than sixteen (16) years old.

Information Relating to Children

Our Platform is not directed to children under the age of eighteen (18), and we do not knowingly collect, use, or disclose personal information from children under the age of eighteen (18) that do not have parental or legal guardian consent to use the Platform. If we ever discover that we have inadvertently collected personal information from children under the age of eighteen (18), we will delete it from our records as soon as possible.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under this Privacy Policy. Unless permitted by the Regulations, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the Regulations that can result in different prices, rates, or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (California Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@trooptravel.com.

Cookies and Other Tracking Technologies

We may use cookies to keep track of your preferences and Account profile information, or to engage in certain retargeting activities that we feel will better enhance your User experience and the efficiency and effectiveness of the Platform. Cookies are also used to collect general usage and volume statistical information that does not include personal information.

Cookies are small pieces of information that are stored as text files by your Internet browser on your computer’s hard drive. Most Internet browsers are initially set to accept cookies. You can set your browser to refuse cookies from websites or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Platform. Please note that certain options you select are browser- and device-specific.

A more detailed list of the cookies we currently, or in the future may, use and how we use, or may use, them are as follows:

Security: We secure the Platform with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Use, such as unauthorized access or activity.
Localization: We use some cookies to help us provide localized experiences, such as displaying the Platform in the local language.
Platform Features and Services: We use certain cookies to provide greater functionality to the Platform and help us deliver our products and services.
Performance: We use performance cookies to help us route traffic between servers and understand how the Platform is performing so we can provide users with the best experience possible.
Analytics and Research: We use certain cookies and other technologies to help us understand, improve, and research features and content on the Platform.

Web Beacons

Our Platform may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Platform is used. We use this aggregated information to understand and optimize how the Platform is used.

Link to Third Party Websites

The Platform may include links to other websites, mobile applications or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein. Such links are not an endorsement by TROOP of those Third Party Sites and/or the products or services they offer. TROOP makes no representations or warranties with respect to, nor is TROOP responsible for the privacy policies of, any Third Party Sites. If you decide to click on any such links or access any Third Party Sites appearing on the Platform, you do so at your own risk.

Do Not Track Requests

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Security

The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We follow generally accepted industry standards to protect your information, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to keep current our security technology, the complete and absolute security of any information collected, stored or used by us cannot be guaranteed. If you have any questions about security on our Platform, you can contact us at privacy@trooptravel.com.

Email Notifications and Opt-Out

We maintain a strict ‘no-spam’ policy. Unless your organization requested otherwise on your behalf or you specifically opt-out as provided herein, by using our Platform you expressly agree that we may use your information to contact you by email in order to deliver information relevant to your use of the Platform such as administrative notices, product/service enhancements, or newsletters. You may choose to stop receiving these email communications from us by following the instructions included in such communications or by contacting us at privacy@trooptravel.com. If you are having problems unsubscribing please contact us at privacy@trooptravel.com and you will be removed within seven (7) business days.

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices from time to time in our sole discretion. If we make any material changes to this Privacy Policy, we will notify you by: (i) sending an email to the primary account address on file; and/or (ii) displaying a conspicuous in-application notice upon your next login. We will also update the “Last Updated” date at the top of this Privacy Policy. For material changes, your continued access to the Platform after the effective date will require your affirmative acceptance of the updated Privacy Policy via an in-application prompt before you can continue using the Platform.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which TROOP collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under the Regulations, please do not hesitate to contact us at:

Email: privacy@trooptravel.com

Postal Address:

Troop Travel, Inc.

Attn: Troop Travel Privacy

251 Little Falls Drive

Wilmington, DE 19808

Last updated on May 13, 2026