S2 MOUNTAIN ADVENTURES (“S2MA”) DATA USE AND PRIVACY POLICY

Effective Date: January 31, 2024

Thank you for using the S2MA Website! We want your experience to be safe, enjoyable and transparent.

Please read our Data Use and Privacy Policy (“Policy”) carefully before using our website or sharing information with us. Protecting your privacy is very important to us. This Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services” or “Service”). We respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you.

1. Information You Provide and Information Collection: When you make a booking or inquiry about an S2MA trekking or climbing program, we may collect personal information such as your name, contact details, emergency contact information, home location, passport information, medical history, payment details, and other information to process a booking. If you communicate with us via email or through our website, we may retain the content of your messages. Like many websites, we may collect certain information automatically, including your IP address, browser type, device information, and cookies to enhance your experience and improve our services.

We collect personal information about you (“Personal Information”) as follows:

Account Information: When you create an account on our website, we will collect information associated with your account, including your name, contact information, account credentials, emergency contact information, medical history, passport information, payment card information, and transaction history, (collectively, “Account Information”).

User Content: When you use our Services, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).

Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send.

Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your identity (collectively, “Other Information You Provide”)

Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we receive the following information about your visit, use, or interactions, including:

Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.

Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.

Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.

Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.

Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

2. Use of Information: We use the information we collect to: a) provide and manage S2MA sales and services; b) communicate with you regarding bookings, inquiries, updates, and services you requested; c) improve our website, services, and customer experience; and c) to provide, administer, maintain and/or analyze the Services; d) to communicate with you; including to send you information about our Services and events; e) to develop new programs and services; f) to prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks; g) to carry out business transfers; and h) to comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

3. Data Sharing: We respect your privacy and ownership of your personal information. We do not sell, trade, or otherwise transfer your personal information to outside parties unless necessary for providing our services or required by law. We may share information with S2MA associate service providers or partners who assist in operating our website or providing services to you.

4. Data Security: We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites. S2MA will retain your personal information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

5. Cookies and Tracking Technologies: We may use cookies and similar tracking technologies to enhance your experience on our website, analyze trends, and gather information about user interactions. You can control cookies through your browser settings.

6. Third-Party Links: Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of these websites. We encourage you to review their privacy policies before providing any personal information. Links to other websites not operated or controlled by S2MA, including social media services have different privacy practices. The information that you share with third-party sites is governed by the specific privacy policies and terms of service of those sites and not by this Policy. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the third- party site directly for information on their privacy practices and policies.

7. Children's Privacy: Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe that we have inadvertently collected information from a child, please contact us at Adventures@S2MountainAdventures.comto remove the information.

8. International Users: By using our Service, you understand and acknowledge that your personal information will be processed and stored in our facilities and servers in the United States and may be disclosed to our service providers and affiliates in other jurisdictions. Our legal bases for processing your Personal Information include: a) performance of a contract with you when we provide and maintain our Services; b) when we process account information, content, and technical information solely to provide our Services to you. This information is necessary to provide Services to you. If you do not provide this information, we may not be able to provide Services to you; c) our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services. This may include the processing of account information, content, and social information; d) your consent when we ask for your consent to process personal information for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time; e) compliance with legal obligations when we use your personal information to comply with applicable law or when we protect our or our affiliates’, users’, or third parties’ rights, safety, and property. We will only transfer personal information pursuant to a legally valid transfer mechanism.

9. Your Choices: You have the right to access, correct, or delete any personal information retained by S2MA. Please contact us at Adventures@S2MountainAdventures.comif you wish to exercise these rights or have any concerns about your data. Depending on location, individuals may have certain statutory rights in relation to their personal information. For example, you may have the right to: a) access your personal information and information relating to how it is processed; b) delete your personal information from our records; c) rectify or update your personal information; d) transfer your personal information to a third party (right to data portability); e) restrict how we process your personal information; f) withdraw your consent, where we rely on consent as the legal basis for processing, at any time; g) object to how we process your personal information; and h) lodge a complaint with your local data protection authority.

10. Modifications to Terms: We reserve the right to modify these Terms at any time. Any changes are effective immediately upon posting on our website. Your continued use of our website after changes constitutes acceptance of the updated Terms. Your continued use of our website constitutes acceptance of the updated Policy.

11. Governing Law: These Terms are governed by and construed in accordance with the laws of Virginia, without regard to principles of conflict of law.

12. Contact Us: If you have any questions or concerns about these Terms, please contact S2MA at Adventures@S2MountainAdventures.com.

Thank you for trusting S2MA. Your privacy is important to us, and we understand that your confidence is earned.