This California Applicant and Employee Privacy Policy (“Privacy Policy”) explains how Inspirato LLC and its affiliates and subsidiaries (hereinafter, “Inspirato”, “we”, “us”, or “our”) handle information that may be used to identify you directly or indirectly (“Personal Information”) in connection with your application, employment, and any post-employment activities. This Privacy Policy describes our business purposes in using your Personal Information and applies to employees, applicants, and contractors located in California.

 

California Consumer Notice of Collection

This notice of collection is provided to all California applicants, employees, contractors, and other individuals subject to this Privacy Policy. If you are a contractor some of this information may not be applicable to you. Please reference specific topics about your Personal Information below:

Where We Get Your Personal Information From
The Personal and Sensitive Personal Information That We Are Collecting
How Your Personal and Sensitive Personal Information is Used
Disclosure of Your Personal Information
Retention of Your Personal Information
Protection of Your Personal Information
Your Rights Regarding Your Personal Information
Contact Us
Updates

 

Where We Get Your Information From

Inspirato collects information about you from the following sources: 1) directly from you; 2) prior employers, references, recruiters, job-related social media platforms; 3) third-party sources of demographic information; 4) third-party companies, such as background check companies; and 5) claim administrators and government agencies. Depending on Inspirato’s interactions with you, we may or may not collect all of the information identified about you.

 

The Personal and Sensitive Personal Information That We Are Collecting

We are collecting the following information:

• Contact information/identifiers, including name, personal contact information, emergency contact information, date of birth, bank account information.
• Organizational data, including work contact details (e.g., address, email, phone number), position/title, job function, employee ID, access passcodes, work eligibility information.
• Employment-related information, including benefits information and performance data.
• Professional information and education data, including prior employment and educational history.
• Compliance and disciplinary information.
• Sensitive Personal Information (where permitted and in accordance with applicable law and in certain instances only where you voluntarily provide such information):
  • Social Security Number,
  • Driver’s license number,
  • Passport Numbers
  • Health and medical related data,
  • Race and ethnic origin,
  • Sexual orientation,
  • Company username and password,
  • Contents of certain email or other communications made on company IT equipment, and
  • Criminal history and drug and alcohol test results.
  • Information concerning travel or other reimbursements or purchases from Inspirato.
  • Internet or network activity information, such as browsing history and interactions with our online systems and websites and any Personal Information that you provide while accessing Inspirato’s computer systems, such as personal credit card information and passwords.
  • Geolocation data, such as device location from usage of Inspirato’s devices.
  • Audio, electronic, visual, and similar information.

  In general, you are required to provide such Personal Information, except in limited instances when we indicate that the provisions of certain information is voluntary (e.g., in connection with employee satisfaction surveys). Not providing Personal Information where required may prevent Inspirato from carrying out the employment relationship or processing your application with you and may require Inspirato to terminate your employment or your application where permitted by applicable law.

  In some instances, the provision of the Sensitive Personal Information listed above is voluntary. We will let you know when that is the case, and if you decide not to share Sensitive Personal Information that is voluntary, not doing so will not impact your employment with Inspirato.

   

  How Your Personal and Sensitive Personal Information is Used

  We may use Personal and Sensitive Personal Information:

  • To operate, manage, and maintain our business;
  • For hiring, retention, and employment purposes;
  • To otherwise accomplish our business purposes and objectives, including, for example:
    • Emergency services;
    • Conducting research, analytics, and data analysis;
    • Administering and providing compensation;
    • Managing mergers and acquisitions, and other business reorganizations and job eliminations, business transfers, and potential divestments;
    • Administering the workforce;
    • Recruiting and staffing activities;
    • Maintaining our facilities and infrastructure;
    • Quality and safety assurance measures;
    • Conducting risk and security controls and monitoring;
    • Protecting confidential and trade secret information;
    • Detecting and preventing fraud;
    • Performing identity verification;
    • Performing accounting, audit, and other internal functions, such as internal investigations;
    • Complying with the law, legal process, and internal policies;
    • Maintaining records;
    • Claims processing;
    • Responding to legal requests for information and subpoenas; and
    • Exercising and defending legal claims.
    • Any other purposes authorized by the California Privacy Protection Agency, California or Federal law.

    We may or may not have used Personal and Sensitive Personal Information about you for each of the above purposes. With regard to Sensitive Personal Information, we only use your Sensitive Personal Information to provide you with the requested products or services and to administer your employment.

     

    Disclosure of Your Personal Information

    Inspirato may disclose all categories of Personal Information listed above to the following parties:

    • Within Inspirato. We may disclose information to other affiliates and subsidiaries in the course of our normal business operations and as needed to address our global structure.
    • Customers and Third Party Business Partners. As necessary in connection with business operations, Personal Information may be disclosed to customers and other third parties.
    • Service Providers. As part of normal business operations, Inspirato may disclose Personal Information to third party service providers, including in connection with human resources support, benefits providers (e.g., health insurers), payroll-related tasks, information technology and security support, and other normal business operations support.
    • Government Entities, Regulators, or External Advisors. Inspirato may disclose Personal Information to governmental agencies and regulators (e.g., tax authorities, social security administration), external advisors (e.g., lawyers, accountants, and auditors), courts and other tribunals, government authorities, or other third parties in response to a subpoena or other legal request, to the extent required or permitted by applicable law.
    • Other Disclosures with Your Consent. We may ask if you would like us to disclose your Personal Information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, such as employee benefit partners and providers and occupational health providers.
    • Business Transactions. In the event of mergers, reorganizations or similar corporate restructuring activities, we may disclose information with that company. In some instances, this may include your Personal Information.

     

    Retention of Your Personal Information

    Inspirato will retain your Personal Information, including Sensitive Personal Information, only for as long as it is necessary to fulfill the above-mentioned Processing Purposes, or as required to comply with applicable laws. We consider the following criteria to determine the appropriate retention period for your Personal Information: the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements. Even when the recruitment and pre-employment screening activities are complete, we may retain your Personal Information for various reasons, including but not limited to compliance with law and future employment opportunities.

     

    Protection of Your Personal Information

    Your Personal Information held by Inspirato will be kept confidential in accordance with applicable Inspirato policies and procedures. We have put in place reasonable technical and organizational security measures that are designed to protect your Personal Information from loss, harm or unauthorized disclosure.

     

    Your Rights Regarding Your Personal Information

    You have certain rights regarding your Personal Information as detailed below:

    (i)   Access and Portability: You have the right to request access to Personal Information we hold about you. Specifically, you have the right to request access to information about the categories of Personal Information concerned and categories of recipients to whom the Personal Information has been or will be disclosed, and the sources from which we receive that Personal Information among other information. You generally have the right to receive this Personal Information, in a structured, commonly used, and machine-readable format so you can transmit this Personal Information to another entity.

    (ii)  Correction: You have the right to request correction of inaccurate Personal Information we may have about you.

    (iii) Deletion: You have the right to request that we delete your Personal Information.

    (iv) Opt out of the Sale or Sharing of Personal Information: We do not currently, nor have we in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. We do not knowingly sell or share the Personal Information of individuals under the age of 16.

    (vi) Sensitive Personal Information: We do not collect or disclose Sensitive Personal Information for purposes other than those which cannot be limited under California law.

    (vii)Non-discrimination: We do not discriminate against employees who exercise any of their rights described in this Privacy Policy, nor do we retaliate against employees who exercise these rights.  Please note Inspirato may require the use of your Personal Information to administer your employment relationship with us. Therefore, in some instances, we may not be able to process your request.

    If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.

    A person authorized to act on your behalf may make a verifiable request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

    Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Policy. If you do not agree with our decision or response, you may appeal our decision to the applicable regulatory authority.

     

    Contact Us

    Questions, comments, requests, or complaints regarding this Privacy Policy and/or our use of your Personal Information should be addressed to the contact information below.

     

    Inspirato LLC
    Attn: Legal Department
    1544 Wazee St.
    Denver, CO 80110
    legal@inspirato.com

     

    Updates

    We may update this Privacy Policy to reflect changes in the way we process Personal Information. We will notify you about such changes in the way we use your Personal Information in compliance with applicable law.

    This Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

     

    Effective Date. June 16, 2023
    Last Updated Date. June 16, 2023