Privacy Policy

Tripolo respects your privacy and is committed to protecting personal information collected through our websites, mobile applications, and related services (collectively, the “Tripolo Platform”). This Privacy Policy explains how Tripolo collects, uses, shares, and safeguards personal information, and describes the choices available to you.

This Privacy Policy applies to Travelers. Guides are covered by a separate policy published by 趣菠萝科技（深圳）有限公司, as explained in Section 1.

1. Who We Are and Who is Responsible for Your Information

This Privacy Policy applies to Travelers. “Tripolo,” “we,” “us,” and “our” mean Tripolo, Inc., which is responsible for Traveler personal information regardless of where you reside. Guides contract with 趣菠萝科技（深圳）有限公司, an independent company under no common ownership with Tripolo, Inc., and their personal information is governed by that company’s separate privacy policy. Both entities are identified in Schedule 1 at the end of this Policy.

Tripolo, Inc. acts as the data controller of Traveler personal information for the purposes of applicable data protection laws. The two companies are independent controllers; neither acts as processor for the other.

2. Personal Information We Collect

We collect personal information in the categories described below. The information we collect depends on how you use the Tripolo Platform and the features you choose.

2.1 Information You Provide

When you create an account, use Tripolo, or contact us, you may provide:

Account and profile information: name, email, phone number, password, profile photo, preferred language(s), and profile details you choose to add.

Booking information: trip destination, dates, group size, booking requests, and any information you provide to a Guide or Traveler related to a Reservation.

Payment information: payment method details (e.g., card or wallet tokens handled by our payment partners), billing address, and transaction amounts. Tripolo does not store your full card number.

Identity verification information (if required): government-issued ID details and/or a selfie, where needed for fraud prevention, compliance, or payout eligibility.

Communications: messages and content you send through Tripolo (including with customer support).

User content: reviews, ratings, photos, and other content you upload or post.

Customer Support interactions: information you share when you contact customer support; if we record calls where permitted by law, we will notify you as required.

If you provide information about other people (such as co-travelers), you confirm you have permission to provide that information.

2.2 Information We Collect Automatically

When you access or use the Tripolo Platform, we automatically collect:

Usage data: pages and Service Pages viewed, searches, filters applied, clicks, bookings and booking status, messages sent (metadata), time spent, and interaction patterns.

Device and technical data: device model and operating system, app version, browser type and settings, language and region settings, mobile network information, and unique device or installation identifiers.

Log and connection data: IP address, access times, referring pages, crash reports, diagnostic logs, and error data.

Approximate location derived from IP address: used to set language defaults, show relevant Service Pages, and support fraud prevention.

Cookies and similar technologies: used to keep you signed in, remember preferences, measure performance, and detect fraud. See the Cookie Policy at https://tripolo.com/legal/cookiepolicy.

We do not collect device location. The Tripolo application does not read your device’s GPS or other device-based location, does not track your movements, and does not collect location in the background. Map features are used only to display and select places; coordinates come from the place you or a Guide selects, not from your device.

2.3 Information We Receive from Third Parties

We may receive personal information from:

Payment processors and financial partners, relating to transaction status, fraud signals, and chargebacks.

Identity verification and fraud-prevention providers where needed to protect the Platform and comply with legal obligations.

Other users (e.g., reports or complaints) and public/legal sources where permitted by law.

2.4 Sensitive Information

We do not intentionally collect sensitive personal information (such as health data) unless you choose to provide it and it is necessary for a specific purpose (for example, to address a safety concern or support request). Where required by law, we will obtain your consent or provide additional notices.

3. How We Use Personal Information

Tripolo uses personal information only for legitimate business purposes and in accordance with applicable data protection laws. The purposes for which we process personal information depend on how you use the Tripolo Platform.

3.1 Operating the Tripolo Platform

We use personal information to operate and maintain the Tripolo Platform, including to:

• create and manage user accounts
• enable Travelers and Guides to connect, communicate, and complete bookings
• process payments and payouts
• provide customer support and respond to inquiries
• send transactional messages such as booking confirmations, updates, and security notifications

3.2 Improving and Developing Our Services

We may use personal information to:

• understand how users interact with the Tripolo Platform
• identify bugs, errors, or performance issues
• improve existing features and develop new ones
• train customer support and improve service quality

Any analysis performed for these purposes is conducted in a manner consistent with applicable law.

3.3 Personalization and User Experience

Where appropriate, we may use personal information to:

• personalize search results or recommendations
• tailor content, language, or settings based on your preferences
• improve relevance and usability of the Tripolo Platform

You may manage certain personalization settings through your account where available.

3.4 Safety, Security, and Platform Integrity

We process personal information to help keep Tripolo and its users safe, including to:

• detect, prevent, and address fraud, abuse, or misuse of the Platform
• enforce our Terms of Service and related policies
• verify information provided by users where necessary
• investigate complaints, disputes, or suspected violations
• protect the rights, safety, and property of Tripolo, its users, and the public

Automated tools may be used to support these purposes, but material decisions that significantly affect users are subject to appropriate safeguards as required by law.

3.5 Legal and Regulatory Compliance

We may process personal information as necessary to:

• comply with applicable laws, regulations, and legal obligations
• respond to lawful requests from courts, regulators, or authorities
• establish, exercise, or defend legal claims
• fulfill tax, accounting, and reporting obligations

3.6 Communications and Marketing

Subject to applicable law and your preferences, we may use personal information to:

• send service-related communications
• provide updates about Tripolo features or changes
• send promotional or marketing messages

You may opt out of marketing communications at any time by following the instructions in the message or through your account settings.

3.7 Payments and Financial Operations

Personal information is used to support payment-related activities, including to:

• facilitate transactions between Travelers and Guides
• issue payouts and refunds
• prevent fraud, chargebacks, and unauthorized transactions
• comply with financial, anti-money laundering, and sanctions requirements

Payment processing is handled by trusted third-party payment providers, and Tripolo does not store full payment card numbers on its own systems.

3.8 No Sale of Personal Information

Tripolo does not sell personal information. We do not share personal information with third parties for their independent marketing purposes without your consent, except as described in this Privacy Policy.

4. Sharing and Disclosure

Tripolo shares personal information only as necessary to operate the Tripolo Platform, provide services you request, comply with legal obligations, and protect Tripolo and its users. We do not sell personal information.

4.1 Sharing Between Travelers and Guides

To facilitate bookings and delivery of Guide Services, certain personal information is shared between Travelers and Guides, including:

• profile information (such as name, profile photo, and language preferences)
• booking details (such as dates, location, and group size)
• messages exchanged through the Tripolo Platform
• reviews and ratings submitted after a completed Guide Service

The scope of information shared is limited to what is reasonably necessary to complete the Reservation and provide the Guide Service.

4.2 Sharing with Service Providers

We share personal information with third-party service providers that help us operate and support the Tripolo Platform. The categories of provider we engage are set out in Section 5.1.

These service providers are authorized to process personal information only for the purposes specified by Tripolo and are contractually required to protect the information and use it only in accordance with applicable law.

4.3 Sharing for Legal, Safety, and Compliance Purposes

We may disclose personal information where we reasonably believe such disclosure is necessary to:

• comply with applicable laws, regulations, or lawful requests
• respond to subpoenas, court orders, or regulatory inquiries
• enforce our Terms of Service and related policies
• investigate, prevent, or address fraud, security issues, or illegal activity
• protect the rights, property, or safety of Tripolo, its users, or the public

Where permitted by law, we may notify you of such disclosures.

4.4 Corporate Transactions

If Tripolo is involved in a merger, acquisition, reorganization, sale of assets, financing, or similar transaction, personal information may be disclosed or transferred as part of that transaction, subject to applicable law and appropriate confidentiality protections.

4.5 International Data Transfers

Tripolo, Inc. stores and processes Traveler personal information on servers located in the United States.

When you make a booking, personal information necessary to deliver the Guide Service is transferred to 趣菠萝科技（深圳）有限公司 in the People’s Republic of China, which operates the Guide side of the platform and makes it available to your Guide. The information transferred is limited to: your name or display name, party size, booking date and time, meeting point, any service requirements you provide (for example an accessible route, an adjusted pace, or food arrangements — we do not ask for health information), and your in-Platform messages.

The following are not transferred to China: your payment card or financial account details, government-issued identification, and full contact details such as your telephone number. Communication with your Guide takes place through in-Platform messaging; telephone numbers are not exchanged.

趣菠萝科技（深圳）有限公司 is an independent company under no common ownership with Tripolo, Inc. The transfer is governed by a written data transfer agreement imposing confidentiality, purpose limitation, security, and deletion obligations.

Transfer does not extend retention. Information transferred between the two jurisdictions is retained for the same periods that apply to it domestically, as set out in Section 8. Transferring information across a border does not cause it to be kept for longer. Where you ask us to delete information that has been transferred, we instruct the receiving company to delete its copy, and it is contractually required to do so, except where retention is required by law or an open dispute remains.

4.6 No Sale of Personal Information

Tripolo does not sell personal information and does not share personal information with third parties for their own independent marketing purposes without your consent.

5. Third-Party Services and Integrations

Tripolo uses certain third-party service providers to operate, maintain, and support the Tripolo Platform. These service providers are selected and managed by Tripolo and are used as part of Tripolo’s normal platform operations.

5.1 Platform Service Providers

Tripolo engages third-party service providers to support core functions of the Tripolo Platform, which may include:

• payment processing and payouts
• fraud prevention and security monitoring
• cloud hosting, data storage, and infrastructure
• customer support tools
• system monitoring, maintenance, and performance optimization
• map and location services used to display listings, meeting points, or nearby areas

These service providers process personal information only on Tripolo’s behalf and only as necessary to provide their services. They are contractually obligated to protect personal information, maintain appropriate security measures, and process information in accordance with applicable law.

Users do not enter into separate agreements with these service providers through the Tripolo Platform.

5.2 No Independent Use by Service Providers

Tripolo does not permit third-party service providers to use personal information for their own independent purposes, including marketing, advertising, or profiling.

5.3 Third-Party Links

The Tripolo Platform may contain links to third-party websites or services for convenience or informational purposes. Tripolo does not control these third parties, and your interactions with them are governed by their own terms and privacy policies.

6. International Data Handling

6.1 Where Your Information Is Held

Responsibility for personal information on the Tripolo Platform is allocated by role, not by your country of residence: Tripolo, Inc. is responsible for Traveler personal information and holds it in the United States; 趣菠萝科技（深圳）有限公司 is responsible for Guide personal information and holds it in the People’s Republic of China.

Moving to another country does not change which entity is responsible for your information. If you use the Platform in both roles, each entity is responsible for the information associated with that role.

6.2 Cross-Border Transfers

Cross-border transfers occur only when a booking is made, and are limited to the information described in Section 4.5. Sensitive information — payment credentials, financial account details, and government-issued identification — is not transferred between the two jurisdictions.

Where transfers occur, Tripolo implements safeguards required by applicable law, including a written transfer agreement, purpose limitation, access controls, and encryption in transit.

6.3 The Two Contracting Entities

Tripolo, Inc. and 趣菠萝科技（深圳）有限公司 are separate companies under no common ownership. Neither controls the other. Each is independently responsible for its own processing of personal information and for responding to requests concerning the information it holds. Contact details for both appear in Schedule 1 at the end of this Policy.

7. Your Rights and Choices

You may have certain rights regarding your personal information under applicable data protection laws. The rights available to you depend on your place of residence or establishment.

7.1 Access and Correction

You may request access to the personal information Tripolo holds about you and request correction of inaccurate or incomplete information.

Some information may also be reviewed or updated directly through your Tripolo account settings.

7.2 Deletion

You may request deletion of your personal information, subject to applicable law and legitimate business needs. You may also delete your account directly in the Tripolo app through your account settings.

Please note that Tripolo may retain certain information where retention is necessary to:

• comply with legal, tax, or regulatory obligations
• resolve disputes or enforce agreements
• prevent fraud or misuse of the Tripolo Platform
• maintain the integrity of reviews, transactions, or records

Public content such as reviews or ratings may remain visible even after account deactivation, except where removal is required by law or permitted by Tripolo policies.

7.3 Restriction and Objection

Where permitted by applicable law, you may request that Tripolo restrict or limit the processing of your personal information, or object to certain processing activities.

7.4 Data Portability

Where required by law, you may request a copy of certain personal information you have provided to Tripolo in a structured, commonly used, and machine-readable format, or request that such information be transferred to another service provider.

7.5 Consent and Marketing Preferences

Where Tripolo relies on your consent to process personal information, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted before the withdrawal.

You may opt out of promotional or marketing communications at any time by following the instructions in those messages or by adjusting your account settings where available.

7.6 Exercising Your Rights

To exercise your rights, please contact us at: privacy@tripolo.com.

We may need to verify your identity before responding to your request. Tripolo will respond within the timeframes required by applicable law.

7.7 No Retaliation

Tripolo will not discriminate against you or deny services solely because you exercised your rights under applicable data protection laws, except where permitted by law.

8. Data Retention

Tripolo retains personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

8.1 Retention Criteria

The length of time we retain personal information depends on factors including:

• whether you maintain an active Tripolo account
• the nature of your interactions with the Tripolo Platform (such as bookings or payouts)
• the purposes for which the information was collected
• applicable legal, tax, accounting, or regulatory requirements
• the need to resolve disputes, enforce agreements, or prevent fraud or misuse

8.2 Account Information

Personal information associated with your account is generally retained for as long as your account remains active.

If you close your account, Tripolo will delete or anonymize your personal information within a reasonable period, except where retention is necessary for legitimate purposes described in this Section.

8.3 Transaction and Payment Records

Tripolo retains transaction, payment, and payout records as required to:

• comply with legal and regulatory obligations
• support accounting, auditing, and tax requirements
• address chargebacks, disputes, or fraud investigations

Retention periods for such records are determined by applicable law and industry standards.

8.4 Reviews and Public Content

Content you submit for public display on the Tripolo Platform, such as reviews and ratings, may remain visible even after your account is closed.

Tripolo may retain such content to preserve the integrity of the Platform, unless removal is required by law or permitted by Tripolo policies.

8.5 Backup and Residual Copies

Personal information may persist in backup systems or logs for a limited period due to technical and security requirements. Such information is protected and isolated from active systems and is deleted in accordance with Tripolo’s data retention practices.

9. Security

Tripolo takes reasonable and appropriate measures to help protect personal information from unauthorized access, loss, misuse, alteration, or disclosure.

We use a combination of administrative, technical, and organizational safeguards, which may include access controls, encryption where appropriate, internal policies, and limited access to personal information by authorized personnel.

Despite these efforts, no system or method of transmission over the internet is completely secure. Tripolo cannot guarantee the absolute security of personal information, and you use the Tripolo Platform at your own risk.

You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

9A. Children’s Privacy

The Tripolo Platform is not directed to children. You must be at least 18 years old to create an account. We do not knowingly collect personal information from anyone under 18.

Minors may participate in a Guide Service only as part of a booking made by a responsible adult who accompanies them. Where you provide information about a minor in your party (such as a first name or age for safety purposes), you confirm that you are the parent or legal guardian, or are authorised by them.

If we learn that we have collected personal information from a person under 18 other than as described above, we will delete it and terminate the account. If you believe a minor has provided us with personal information, contact privacy@tripolo.com.

9B. United States State Privacy Rights

This Section applies to residents of California, Colorado, Connecticut, Virginia, and other states with comprehensive privacy laws, and supplements the rest of this Privacy Policy.

Categories of personal information we collect: identifiers (name, email address, account identifiers, IP address); commercial information (bookings, transaction history); internet and network activity (usage and device data); approximate location derived from IP address; audio, electronic, or visual information (photos you upload, in-Platform messages); and inferences drawn from the above for personalisation. We collect these from you directly, automatically through your use of the Platform, and from payment and verification providers.

Business purposes: operating and improving the Platform, completing bookings, payments and payouts, customer support, safety and fraud prevention, personalisation, and legal compliance, as described in Section 3.

Categories of recipients: service providers (hosting, payments, identity verification, communications, analytics, mapping); 趣菠萝科技（深圳）有限公司 and, through it, your Guide, for booking fulfilment; and authorities where legally required.

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising. We have not done so in the preceding twelve months.

Sensitive personal information: we do not use or disclose sensitive personal information for purposes other than those permitted without a right to limit under applicable law.

Retention: we retain each category only as long as necessary for the purposes described in this Privacy Policy, and thereafter as required by tax, accounting, and legal obligations.

Your rights: to know, access, and obtain a copy of your personal information; to correct inaccuracies; to delete; to opt out of sale or sharing (we do neither); and to be free from discrimination for exercising these rights. To exercise them, see Section 7.6. You may use an authorised agent by providing written permission; we may require you to verify your identity directly.

If we deny your request, you may appeal by replying to our response or writing to privacy@tripolo.com with the subject line “Privacy Appeal.” We will respond within 45 days.

9C. Washington My Health My Data Act

Tripolo does not collect consumer health data. We do not ask you for diagnoses, symptoms, medical records, medication, or any other health information, and no field on the Tripolo Platform is designed to capture it. We do not collect, infer, or use health information for advertising or profiling, and we do not sell or share any such data.

What we do ask for is the service requirement, not the reason behind it — for example, whether a route needs to be accessible, whether the pace or duration should be adjusted, or what food arrangements are needed. That information is used solely to deliver the Guide Service you booked and is passed to your Guide for that purpose alone.

Booking notes and messages are free-text fields, so we cannot prevent you from typing health information into them. Please do not. If you do, we do not treat it as health data we sought, we do not use it for any purpose other than delivering your booked service, and you may ask us to delete it at any time by writing to privacy@tripolo.com — we will do so except where retention is legally required.

9D. Security Incidents

We maintain administrative, technical, and physical safeguards designed to protect personal information. If a breach of security affecting your personal information occurs, we will notify you and the relevant authorities as required by applicable law, describing the categories of information involved, the likely consequences, and the steps we are taking.

10. Changes to This Privacy Policy

Tripolo may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations.

When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy. If the changes are material, we will notify you by email to the address associated with your account at least thirty (30) days before the change takes effect, and may in addition notify you through the Tripolo Platform. Email is Tripolo’s primary channel for notices under this Section.

Your continued use of the Tripolo Platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy, to the extent permitted by applicable law.

11. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or Tripolo’s handling of personal information, you may contact us using the details below.

Privacy Inquiries

For privacy-related questions or to exercise your rights under applicable data protection laws, please contact:

Email: privacy@tripolo.com

Payment-Related Inquiries

For questions related to payments, refunds, or payouts, please use the contact information provided in the applicable payment terms or contact Tripolo customer support through the Tripolo Platform.

Applicable Tripolo Entity

Tripolo, Inc. is responsible for Traveler personal information. Contact details for both entities are set out in Schedule 1.

Schedule 1 — Tripolo Contracting Entities

Responsibility is allocated by role, not by your place of residence. Tripolo, Inc. is responsible for Traveler personal information; 趣菠萝科技（深圳）有限公司 is responsible for Guide personal information. The two companies are under no common ownership.

United States

Tripolo, Inc.

Email: info@tripolo.com

Responsible for Traveler personal information, which it holds on servers in the United States. Privacy contact: privacy@tripolo.com

People’s Republic of China

趣菠萝科技（深圳）有限公司

Email: info_cn@tripolo.cn

Responsible for Guide personal information, which it holds on servers in the People’s Republic of China. Privacy contact: privacy_cn@tripolo.cn