The OnTheGRiD AI Inc (together with our affiliates, “GRiD”) is a membership club and hospitality platform powered by our AI engine, MILA, which personalizes user experiences across people, places, and programs on The Grid.

This Privacy Policy describes how we collect, use, or disclose personal information we receive through our websites (https://onthegrid.club/), mobile apps, digital applications, physical locations, artificial intelligence (“AI”) systems and related online and offline services we offer (collectively, the “Services”). This policy also describes your choices about the collection and use of your information.

Please read the Privacy Policy carefully before you start to use our Services. By using the Services, you agree to be bound and abide by our posted Terms of Use (“Terms”) together with this Privacy Policy (“Policy”). If you do not agree to both the Terms and this Policy, or if you violate them in any way, you may not access or use the Services. PLEASE SEE SECTION 6 IN OUR TERMS REGARDING YOUR LEGAL RIGHTS IN ANY DISPUTE INVOLVING OUR SERVICES, INCLUDING MANDATORY ARBITRATION AND A WAIVER OF RIGHTS TO A JURY TRIAL OR CLASS ACTION.

How We Collect Information

We may collect information about you by various means, including:

• Directly from you, both online and offline;
• Through your use of our Services, including our websites, mobile apps, physical locations, and other services;
• From other third-party sources and social media platforms that you may use to engage with us, as well as from partners or third parties we work with, in order to supplement information we already possess; and
• By combining information from different sources.

Types of Information We Collect

In order to better provide you with our Services, we may collect the following categories of information:

• Account, profile and subscription information, such as a username and password, your name, mailing address, e-mail address, phone number, biography, photo, professional role, skills/interests, LinkedIn URL, personal preferences (e.g., dietary, room, music, wellness) and communication preferences;
• Professional & Community details, such as your goals, projects, and opt-in profile details used to match you with members, mentors, investors, or companies;
• Bookings & Transactions, such as reservations, event RSVPs, purchases (including autonomous retail), and payment-related records;
• Usage & Device information through your use of our Services, such as app interactions, session logs, device type/OS, crash logs and identifiers for security, performance monitoring, etc.;
• Location (optional), where and as you permit through your device, to provide us with approximate or precise location for check-in, wayfinding, “who’s here now” and other features;
• Wellness Data (optional), such as health-related metrics you choose to share (e.g., sleep or recovery signals), although this is not used for any medical purposes;
• Biometric Data (optional), such as face templates or similar identifiers used strictly for access control where enabled, with separate explicit consent;
• Voice Interactions (optional), such as short voice commands processed to fulfill requests;
• Survey information in response to questions we may send you through the Services, including for research purposes and/or in connection with a contest or promotion;
• User Content may be posted through the Services where we permit (e.g., chats, reviews, photos, and other materials)—this may also include metadata associated with your content (such as location and date/time information embedded in pictures);
• Communications between you and us, such as via e-mail, mail, phone, text or other channels (e.g., messages, support requests, ratings, and meeting feedback);
• Third-Party Data (optional), for example, with your permission, we may enhance your profile using third party providers under contractual safeguards;
• Offline activity you engage in with us, if and where applicable; and
• Online User Activity described in the next section.

If you provide us with information regarding another individual, you represent that you are authorized to give us their information for use in accordance with this Policy.

Online User Activity, Cookies and Information Collected by Other Automated Means

Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We and our service providers may collect information about your use of our Services by such automated means, including but not limited to cookies, pixels, SDKs and other similar technologies.

Cookies and similar technologies can help us automatically identify you when you return to our website or app. Cookies help us review website traffic patterns and improve the website, such as determining the popularity of various Services. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the Services, the information we may collect by automated means includes, for example:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device's telephone number);
• Stored information you affirmatively provide the Services with access to, such as pictures, video and contacts stored on your device; and
• Location information where you choose to provide the Services with access to real-time information about your device’s location.

If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share limited identifiers and device activity obtained via cookies or other such tools with our advertisers and affiliates, where permitted by law.

How We Use Information We Collect

We may use the information we obtain about you for purposes allowed by applicable laws, including:

• Provide our Services to you (account creation and management, identity verification, venue access, payments, security and safety), respond to your requests, questions and comments, and provide customer support;
• To provide a personalized experience (including with MILA, such as recommendations for people, events, dining, wellness, workspaces, and stays) and engagement-based systems (e.g., impact/ecosystem scoring) designed to enhance experiences and recommendations, but not to deny any service;
• For marketing or promotional activities, and to tailor the content we may display to you through our Services and communications, including advertising of products and services that may be of interest to you;
• Operate, evaluate and improve our Services (technology, websites/apps, products and services, third party integrations, develop new services, and diagnosing or fixing issues);
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Inform you about news and changes to our Services, as well as administrative notices such as updates to this Policy, our Terms or other important information about the Services;
• Comply with and enforce as needed applicable legal requirements, industry standards, our security and safety practices, and our policies and contractual rights; and
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns.

We may also use or share information in an anonymized or otherwise aggregated manner for many purposes such as research, analysis, AI training, modeling, marketing, and advertising, as well as improvement of our Services.

Use of AI Technology

In connection with our Services we may train and use MILA or other AI tools with user information and content for certain business purposes, such as to analyze and tailor user experiences and activities, to improve the efficiency, quality, and speed of our business operations, to support communications with customers (such as a chatbot), to generate business content, and to provide more personalized experiences and marketing, but our Services don’t use AI tools in any manner that could be expected to negatively impact customers in a material or unlawful manner. For example, MILA uses algorithms to generate suggestions and coordinate experiences, but users remain in control and can accept, modify, or ignore recommendations at any time. MILA does not make decisions that produce legal or similarly significant effects (e.g., credit, employment, or housing decisions).

Online Advertising

We may serve advertisements, and allow third parties to serve advertisements, through our Services. These advertisements are sometimes targeted and served to particular users and may come from third party organizations called “ad networks.” Ad networks can include a number of third party ad servers, ad agencies, ad technology vendors and research firms. Advertisements served through our Services may be targeted to users who fit a certain general profile category, which may be inferred from information you provide to us or, based on your website or mobile app usage patterns, or based on your activity on other website or online services as may be available to the ad networks.

How We Share Your Information

We will not disclose your personal information to third parties without your consent, except in the following circumstances, as permitted by law.

• If you voluntarily share or submit any User Content including contact information (e.g., name), content (e.g., picture), or commentary (e.g., forums, message boards, chats) for posting through our Services, or link it to any social media platforms, that post and any information associated with it may become available to the public. For example, certain basic profile information may be accessible to all users, and other information may be made accessible only between users who mutually-accepted a connection. Although content or information you post through the Services may be intended for a single other user, for a particular group of users, or for all users, please be aware that we do not control how users may use content they receive, and any content or information you share with another user may be disclosed to other parties or made public. Please review the configurations we make available through the Services to further understand what information or content may be disclosed to other users. We are not responsible for any content or information you share with another user through the Services. See our Terms of Use for more information about how we may use User Content.
• We may share your information with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, AI tools, maintenance and hosting of our Services, payment processors (if applicable), marketing partners, and other vendors). We only provide such vendors with information so they can perform their required functions on our behalf.
• We may share your information with operating partners, such as hotels, clubs, and event hosts to deliver your bookings and experiences. When you direct us to facilitate such bookings and experiences on your behalf, you authorize us to share your information with such operating partners as necessary, and they may use such information subject to their own posted policies and legal requirements.
• We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.
• We reserve the right to transfer the information we maintain in the event we sell or transfer all or a relevant portion of our organization or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Policy.
• We may, from time to time, contact you on behalf of external partners about a particular offering that may be of interest to you. In those cases, your information (e.g., e-mail, name, address, telephone number) is not transferred to the third party. Instead, we may share anonymous data with trusted partners to help perform statistical analysis, and then we would send you an email, postal mail, or other communication on their behalf.

Note that we do not share your text message program enrollment or consent with third parties for their own purposes.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided to us and applicable law.

Your Privacy Choices

All Users

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, reservations, payment receipts, or information about changes to our Terms or other policies.
• Text messages: If you affirmatively consent to receive text messages from us and enroll in such a program, you will receive updates via text unless you opt-out of the text message program. These messages may be unencrypted. Message frequency may vary based on the Services. If at any time you would like to stop receiving text message notifications, please text “STOP” in reply to our message, we will send you a reply message to confirm that you have been unsubscribed and you will no longer receive messages from us. If you want to join again, just sign up as you did the first time and we will start sending messages to you again. If at any time you forget what keywords are supported, just text “HELP” back to us and we will respond with instructions on how to use our service as well as how to unsubscribe.
• Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites and mobile apps may not function correctly.
• User Account: You may access or update your profile information by accessing your account through our Services. You may terminate your user account by contacting us as provided below. We may retain account information or User Content for internal purposes or as otherwise provided in this Policy and our Terms.

State Specific Notices

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia:

In addition to the other disclosures in this Policy, if you are a retail customer residing in one of these states (or a job applicant, current/former employee, contractor or business partner in California), there are specific privacy laws applicable to you as described below. However, given our size and business operations, we may not be subject to such laws in at least some of these states. Therefore, if you make any of the privacy requests described below, we will respond as required by applicable law, and otherwise in our discretion.

• You may request a copy of the following: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; (4) the categories (or identity) of third parties with whom we shared personal information, and the categories of personal information shared; and (5) the specific pieces of your personal information that we have collected, used, disclosed, or sold.
• You may request that we correct your personal information if it is inaccurate, or delete your personal information. Note that deletion requests are subject to certain limitations, for example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for certain other internal business purposes described in this Policy.
• You may opt out of (i) any selling or sharing of your personal information to a third party (excluding service providers or other exceptions permitted by law); (ii) any third-party targeted advertising (i.e., cross-context behavioral advertising); (iii) any use of sensitive personal information (such as precise geo-location or financial information) except for the purposes it was collected and as otherwise permitted by law; or (iv) impactful profiling activities.

To make any of these requests, please contact us via privacy@onthegrid.club with your name, address, and request. You may authorize another person (your “agent”) to submit a request on your behalf the same way. Shortly after you (or your agent) submit a request, we will contact you (via the email address on file for you) with instructions on how to verify the request before we fulfill it. If and to the extent required by privacy laws in your state of residence, we will aim to complete requests as soon as reasonably practicable, consistent with any deadline under applicable law. We may not, and will not, discriminate against anyone for exercising privacy rights provided by applicable laws.

If we deny a privacy request provided by law, you may appeal the decision to us at the contact information provided below. To the extent possible, please describe the basis for your appeal. We will endeavor to provide a prompt response. If we deny an appeal, you can raise any concerns with your state’s Office of the Attorney General.

Residents of California

The categories of information we collect are described above in this Policy, and include: (i) Identifiers such as name, email address, IP address, postal address and phone number, such as if you visit our Services, create an account or engage in a transaction with us; (ii) Commercial information such as any payment activities; (iii) Internet activity such as the Online User Activity described above; (iv) Geolocation data including location enabled services such as WiFi; and (v) Sensitive personal information such as account credentials provided for any Services, and financial information provided for a transaction. California’s privacy law is not limited to retail customers and extends to individuals in other capacities such as job applicants, employees, contractors and business partners.

Due to the nature of these relationships, the collection and use of personal information can vary, but in general terms and in addition to all the disclosures above: (1) Job applicants may provide us with personal information as part of an employment application and review process that includes the applicant’s contact information, education and employment history, resume and cover letter. We do not use this information for any purpose other than to evaluate the individual for employment with us and manage our careers program. Job applicants may provide additional information for routine background checks to a third-party provider of such services, under specific privacy terms and consents that will be provided at the time of collection; (2) Employees receive disclosures during and after onboarding that provides additional details regarding our employee privacy practices; (3) We collect contact information and other personal information reasonably necessary to engage and work with contractors and business partners in the course of a business relationship.

Do Not Track (DNT) is a privacy preference you can set in most browsers but there is no standard interpretation or practice for responding to DNT signals (see https://allaboutdnt.com/ for more information), and we therefore handle all information consistent with this Policy.

Residents of Nevada

We do not sell personal information as defined by Nevada law, but you can submit a request to us at privacy@onthegrid.club.

Links to Other Websites and Third Party Content

Our Services may contain links to other websites, apps, services or social media platforms, including those managed by operating partners, advertisers or sponsors. Please be aware that we are not responsible for the content or privacy practices of such other websites, apps, services and social media platforms, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other organization that may collect or process your personal information.

How We Protect and Retain Information

We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

We apply a general rule of keeping personal information for as long as required to fulfill the purposes for which it was collected including (i) to provide you with our Services, such as to maintain account profiles while active and after termination for the purposes described above, and (ii) as reasonably as necessary for legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

Children

Our Services are not intended for minors under 18 and we do not request or knowingly collect any personal information from minors under 18. We will endeavor to promptly delete any personal information identified as having been collected online directly from minors.

International Considerations

Our Services are primarily controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. However, your data may be processed in the United States or other countries where we or our service providers operate using appropriate safeguards.

Updates to Our Privacy Policy

We may revise or update this Privacy Policy at any time. We will post the updated version on our Services, and may notify you of any significant changes to our Privacy Policy. We will indicate on our Privacy Policy when it was most recently updated. Your continued use of our Services after such updates will constitute an acknowledgment of the change and agreement to abide and be bound by the updated Privacy Policy.

Contacting Us

If you have any questions, concerns or comments about this Privacy Policy, our privacy practices, or if you would like us to update information or preferences you provided to us, please contact us at privacy@onthegrid.club.

This Privacy Policy was last updated October 29, 2026.

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