PRIVACY POLICY

This Privacy Policy describes how Tickeri Inc. and its affiliated companies (collectively, “Tickeri”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:

1. User Data: data relating to event participants (“Ticket Purchasers”) who book tickets using Tickeri’s ticketing platform (“Platform”) or people who purchase merchandise on the website (“Shoppers”); (collectively, “Users”).
2. Promoters, Organizers and Artists Data (“Organizers”): data relating to artists, promoters, managers and other individuals who engage with the Platform and create events on tickeri.com.
3. Sites Usage, Customer Relationship Management (“CRM”) & Prospect Data: data relating to visitors of our website (www.tickeri.com), participants at our company events, and any other prospective user, organizer or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, newsletter, online ads and content, emails, integrations or communications under our control (the “Sites”, and collectively with the Platform, the “Services”).

Specifically, this Privacy Policy describes our practices regarding the following with respect to our Services:

1. Data Collection & Processing
2. Data Uses
3. Data Location
4. Data Retention
5. Data Disclosure
6. Cookies and Data Collection Technologies
7. Communications
8. Data Security
9. Data Subject Rights
10. Data Controller/Processor
11. Additional Notice & Contact Details

If you are a Ticket Purchaser, Shopper, Organizer or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.

1. Data Collection & Processing

   When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

   Sometimes we collect personal data automatically when an individual interacts with our Services and sometimes, we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as Service Providers), even before our first direct interaction.

   1. User Data: Tickeri collects the following personal data relating to Ticket Purchasers and Shoppers who engage with our Services:
      • Ticketing Platform: full name, billing address, billing information, email address, phone number, credit card number, IP address;
      • El Shop: full name, billing address, billing information, email address, phone number, credit card number, IP address, shipping address;
   2. Promoters, Organizers and Artists Data: Tickeri collects the following personal data relating to Organizers:
      • Ticketing Platform: full name, social security number, shipping address, billing address, financial data, date of birth, contact details;
   3. Sites Usage, CRM & Prospect Data. We may collect and generate the following types of personal data concerning our website visitors, Customers, partners and prospective Customers (collectively, “Non-Services Related Data”).
      • Sites Usage Data - connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
      • Organizer Account Data - contact details, contractual and billing details relating to our Organizers, which may also contain the details of their internal focal persons who directly engage with Tickeri on behalf of their organization or artist (e.g. the account administrators, billing contacts and authorized signatories on behalf of the Organizer, as well as the needs and preferences of the Organizer, as identified to us or recognized via our engagement with them);
      • CRM and Prospective Customer Data - contact and business details, our communications with Users and Organizers and prospective Users and Organizers, as well as any needs, preferences, attributes and insights relevant to our potential engagement.
2. Data Uses

   We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).

   If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@tickeri.com.

   Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

   User and Organizer personal data

   • To facilitate, operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests);
   • to provide our Users and Organizers with assistance and support, to test and monitor the Services, or diagnose or fix technology problems (Performance of Contract; Legitimate Interests);
   • To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further personalization capabilities (Performance of Contract; Legitimate Interests);
   • To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners (Legitimate Interests; Consent);
   • To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests);

   User, Organizer and Prospect personal data

   • To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services, including through the utilization and optimization of Machine Learning capabilities (Legitimate Interests);
   • To contact our Users, Organizers and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
   • To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);
   • To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests);
   • To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);
   • To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
   • For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
3. Data Location

   We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States of America, Europe and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

   While privacy laws may vary between jurisdictions, Tickeri is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

4. Data Retention

   We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

   To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

   If you have any questions about our data retention policy, please contact us by e-mail at privacy@tickeri.com.

5. Data Disclosure

   We disclose personal data in the following ways:

   Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

   Sharing Personal Data with our Organizers: In order to provide our Services, we may share personal data of our Users with our Organizers. In such cases, sharing such data means that the account administrator(s) of the Organizer may access it on behalf of the Organizer for the provision of the Services.

   Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

   Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Tickeri, any of our Users or Organizers, or any members of the general public.

   Our Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Tickeri or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

   For the avoidance of doubt, Tickeri may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Cookies and Data Collection Technologies

   We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.

   Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

   We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access our Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

   Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.

   For more information, please review our Cookie Policy.

   We also use web analytics tools, including Google Analytics. These tools help us understand Users’ and Organizers’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout.

   Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

   We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

   Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

   Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our User, Organizer or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

   If you do not wish to receive such promotional communications, you may notify Tickeri at any time by sending an e-mail to: privacy@tickeri.com, changing your communications preferences in your profile settings whilst being logged to our Services, or by following the “unsubscribe”, “change e-mail preferences” or similar instructions contained in the promotional communications you receive.

8. Data Security

   We implement systems, applications and procedures designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

9. Data Subject Rights

   Individuals have rights concerning their personal data. Please contact us by e-mail at: privacy@tickeri.com, if you wish to exercise your privacy rights under any applicable law, including the California Consumer Privacy Act (CCPA) or the EU or UK General Data Protection Regulation (GDPR), such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Tickeri, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.

   Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).

   We may redact from the data which we will make available to you, any personal data related to others.

10. Data Controller/Processor

    Certain data protection laws and regulations, such as the CCPA, the EU GDPR and the UK GDPR, typically distinguish between two main roles for parties processing personal data: the “business” (or under the GDPR, “data controller”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

    Tickeri is the “data controller” of User, Organizer and Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.