Effective Date: May 1, 2026

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1. Introduction

Unleesh, LLC (“Unleesh,” “we,” “us,” or “our”) operates a group travel and experience management platform (the “Platform”), including:

• Mobile applications

• Websites (including www.unleesh.com, app.unleesh.com, web.unleeshadmin.com, et al.)

• Associated services, features, and content

 

This Privacy Policy explains how we collect, use, disclose, and protect Personal Information.

 

This Policy is designed to comply with:

• GDPR (EU/UK)

• CPRA/CCPA (California)

• COPPA (U.S. children’s privacy law)

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2. Roles: Controller vs. Processor 

Unleesh operates in two roles:

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2.1 When Unleesh is a Data Controller

We act as a controller when we:

• Manage user accounts

• Operate the Platform

• Handle support, analytics, and marketing

2.2 When Unleesh is a Data Processor

We act as a processor when:

• A Path Administrator (e.g., nonprofit, school, travel operator) controls the experience

• We process data on their behalf

In these cases:

• The Administrator is the Data Controller

• Unleesh processes data under their instructions

 

3. Information We Collect

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3.1 Information You Provide

• Name, email, phone number

• Username, password

• Profile photo

• Date of birth

• Travel and registration details

• Emergency contact information (if applicable)

3.2 User Content

• Posts, photos, videos, audio

• Messages and engagement in Paths

• Metadata (timestamps, geolocation if enabled)

Content visibility depends on Path settings.

3.3 Payment Information (Stripe Integration)

We use Stripe, Inc. as our third-party payment processor.

When you make a payment:

• Payment details (e.g., card number) are collected directly by Stripe

• Unleesh does not store full payment card details

We may collect:

• Transaction records

• Billing name and email

• Payment status

• Partial payment identifiers (e.g., last 4 digits)

Stripe processes your data in accordance with:

• PCI-DSS standards

• Stripe’s Privacy Policy

3.4 Automatically Collected Information

• Device type, OS, browser

• IP address

• Usage data and logs

• Cookies and tracking data

3.5 Location Data

With consent, we may collect:

• Precise geolocation

• Location-linked content

 

4. How We Use Information

We use Personal Information to:

• Provide and operate the Platform

• Facilitate travel and group coordination

• Process payments and transactions

• Communicate with users and administrators

• Improve services and user experience

• Ensure safety and compliance

 

5. Legal Bases (GDPR)

For users in the EEA/UK:

• Contract: Delivering Platform services

• Legitimate Interests: Improving and securing services

• Consent: Marketing, cookies, location tracking

• Legal Obligation: Compliance with laws

 

6. Sharing of Information

We may share data with:

6.1 Path Administrators

Organizations managing a Path may access user data.

6.2 Other Users

Based on Path visibility settings (public/private).

6.3 Service Providers

• Stripe (payments)

• Cloud hosting providers

• Analytics providers

6.4 Legal & Safety

• Law enforcement or regulators

• To protect rights, safety, or property

6.5 Business Transfers

• Mergers, acquisitions, or asset sales

 

7. California Privacy Rights (CPRA/CCPA)

If you are a California resident, you have the right to:

7.1 Right to Know

Request:

• Categories of personal information collected

• Sources of data

• Business purposes

• Categories of third parties

7.2 Right to Delete

Request deletion of your personal information (subject to legal exceptions)

7.3 Right to Correct

Request correction of inaccurate data

7.4 Right to Opt-Out of Sale/Sharing

We do not sell personal information.
If this changes, we will provide a “Do Not Sell or Share” link.

7.5 Right to Non-Discrimination

You will not be penalized for exercising your rights.

7.6 Sensitive Personal Information

We only use sensitive data (e.g., location, health-related travel data if applicable) as necessary to provide services.

 

8. Data Processing Addendum (DPA) Overview

For enterprise clients and Path Administrators:

Unleesh commits to:

• Processing data only on documented instructions

• Ensuring confidentiality of personnel

• Implementing appropriate technical and organizational security measures

• Assisting controllers with:

  • Data subject rights requests

  • Breach notifications

  • Compliance obligations

• Entering into Standard Contractual Clauses (SCCs) where required

A formal DPA is available upon request for customers.

 

9. International Data Transfers

We may transfer data outside your country, including to the United States.

Safeguards include:

• Standard Contractual Clauses (SCCs)

• Contractual protections with vendors

 

10. Data Retention

We retain data only as long as necessary to:

• Provide services

• Fulfill contractual obligations

• Comply with legal requirements

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11. Your Rights (Global)

You may request to:

• Access your data

• Correct inaccurate data

• Delete your data

• Restrict or object to processing

• Transfer your data

• Withdraw consent

Contact: info@unleesh.com

 

12. Cookies and Tracking

We use cookies for:

• Functionality

• Analytics

• Performance

You can control cookies via browser settings.

 

13. Security

We implement:

• Encryption in transit

• Access controls

• Secure cloud infrastructure

However, no system is 100% secure.

 

14. Children’s Privacy (COPPA)

• The Platform is not directed to children under 13

• We do not knowingly collect data from children under 13 without parental consent

If discovered:

• Data will be deleted or parental consent obtained

Parents may:

• Access

• Delete

• Restrict use of their child’s data

Contact: info@unleesh.com

 

15. Third-Party Services

We are not responsible for third-party privacy practices (e.g., Stripe, external links).

 

16. Changes to This Policy

We may update this Policy periodically.
Continued use of the Platform indicates acceptance.

 

17. Contact Information

Unleesh, LLC
Attn: Privacy
110 16th Street, Suite 1300
Denver, CO 80202

Email: info@unleesh.com