TICKET TANNOY PRIVACY POLICY

Effective on April 26, 2018

  1. BACKGROUND

    WAPPA LTD offers a ticketing platform through its website www.tickettannoy.com (“Wappa Site” or “Site”) where you can buy tickets for your favourite events (“Service”). We sell tickets on behalf of promoters, producers, artists, record labels, performers and venues. We refer collectively to these parties who organise or provide events as the “Promoters”.

    We care about privacy and data protection and we are committed to protecting your personal information. We also aim at transparency, we want you to know what data we collect about you and how it is used and shared. Please be aware that, whilst we make our best efforts to keep your personal information safe, no website can be completely secure.

    The following privacy policy (“Privacy Policy”) relates to our use of any personal information regarding you we collect and process via our website, mobile application or any other personal information you provide us in person, via email, telephone, text message, or other means.

    In the Privacy Policy, the terms processing, personal data, data controller, data processor, data subject shall have the same meaning as set out in the Data Protection Act 1998 (“DPA”) as amended, extended or re-enacted from time to time and including all subordinate legislation made from time to time under the DPA or as defined by the Regulation of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) once applicable and/or any corresponding or equivalent national laws or regulations once in force and applicable (“Applicable Data Protection Laws”).

    To learn more about your rights to privacy and data protection, we recommend you visiting the Information Commissioner’ Office (“ICO”) website at https://ico.org.uk/.

  2. KEY TERMS

    To help you understand the content of our Privacy Policy we have summarised some key terms:

    Data Controller means the individual or organisation that, alone or jointly with others, exercises overall control over how Personal Data are processed and the purposes of such treatment.

    Data Processor means any person (other than an employee of the data controller) who processes the data on behalf and under the instruction of the Data Controller.

    Communication Methods mean email, telephone, notices posted on our Site, or any other communication methods.

    Personal Data means data which relates to a living individual who can be identified from such data, or from data and other information which is in the possession of, or is likely to come into the possession of, the Data Controller.

    Processing means obtaining, recording or holding data or carrying out any operation in relation to Personal Data.

    Promoter means the individuals or organisations responsible for organising and/or providing the events listed on the WAPPA Site;

    Third-Party Websites mean websites owned and operated by third parties.

    1. PRIVACY POLICY IN RELATION TO WEBSITE USERS

      The following terms in this paragraph apply only to users of the Site who are not otherwise using our Services.

    2. DATA CONTROLLER

      For the purpose of the processing of your Personal Data in connection with your use of our Site, WAPPA LTD is a Data Controller. Our company is registered in England and Wales, our registration number is 08234095 and our registered office is at 7 Bourne Court, Southend Road, Woodford Green, Essex, IG8 8HD. Our registered VAT number is GB 198 4248 61.

      We are based and mainly operates within the United Kingdom; however, this may change due to future expansion of our business. If you have any query regarding our use of your personal data, please contact us at [email protected].

    3. LEGAL BASIS FOR PROCESSING

      We process your Personal Data on the basis that you have consented to and we have a legitimate interest in such processing. Our legitimate interest includes our commercial interest in offering our Service to the public.

    4. HOW WE USE YOUR PERSONAL DATA

      We use your Personal Data to give you access to our Site and in particular to:

      • a. provide you with information about WAPPA products and services;
      • b. contact you through any Communication Method about our products and services, provided that you have previously consented to us contacting you;
      • c. produce aggregate insights that do not identify you; and
      • d. investigate, respond to and resolve complaints and service issues.
    5. INFORMATION WE COLLECT ABOUT YOU

      We log your visits and your usage data when you visit our Site. In particular, we use internet protocol (“IP”) addresses, cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to identify you or your device. Please read our Cookies Policy to learn more about how we use cookies and similar tracking technologies and how to opt out.

      We receive data from your devices and networks, including location data. When you visit or leave our Site, we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Site from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we respect your settings.

    6. RECIPIENTS OF YOUR DATA

      To provide and develop our Site, we may share your Personal Data with:

      • a. our subsidiaries, as defined by section 1162 of the Company Act 2006 as amended, extended or re-enacted from time to time, provided that our subsidiaries will be subject to the same terms of this Privacy Policy; and
      • b. third parties for maintenance, analysis, audit, payments, marketing and development. Third parties will only have access and use your information as reasonably necessary to perform these tasks on our behalf and they will be bound to non-disclosure obligations and to the terms of this Privacy Policy.

      We may have to disclose your Personal Data if it is reasonably necessary to: (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you; investigate and defend ourselves against any third-party claims or allegations; (iii) protect the security or integrity of our Services.

      We will attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.

      We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

      We may share your Personal Data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.

    7. DATA RETENTION

      We will normally keep your Personal Data for as long as it is necessary to provide you with access to our Site or Services and in any case for a maximum of 3 months from the first collection of your Personal Data.

    8. CROSS-BORDER DATA TRANSFERS

      We do not transfer, store or process your Personal Data at destinations outside the European Economic Area (“EEA”).

    1. PRIVACY POLICY IN RELATION TO USERS OF OUR SERVICE

      The following terms in this paragraph apply only to users of our Service.

    2. DATA CONTROLLER

      For the purpose of the processing of your personal data in connection with the Service and WAPPA Site, WAPPA is a data controller.

      Our company is registered in England and Wales, our registration number is 08234095 and our registered office is at 7 Bourne Court, Southend Road, Woodford Green, Essex, IG8 8HD.

      Our registered VAT number is GB 198 4248 61.

      We are based and mainly operates within the United Kingdom.

      If you have any query regarding our use of your personal data please contact us at [email protected].

    3. LEGAL BASIS FOR PROCESSING

      LEGITIMATE INTEREST

      We process Personal Data of users of our Service on the basis that we have a legitimate interest in such processing that includes our commercial interest in providing you with our Service.

      CONSENT AND PERFORMANCE OF A CONTRACT

      Furthermore, we may process Personal Data of users of our Service on the basis that: (i) they have consented to such processing; and/or (ii) it is necessary for the entry into, or performance of, a contract or in order to take steps at their request prior to the entry into a contract.

    4. INFORMATION WE HOLD

      UPON REGISTRATION

      When you open a customer account with us, we collect the followings Personal Data: your name, your email address, your DOB, your password, and, in cases where postage is required, also a delivery address.

      PAYMENT

      In order to process the payment for an order placed with us, we also collect: the name of the card owner, the card details and the billing address.

      ADDITIONAL INFORMATION

      From time to time we may need to ask you, on behalf of the relevant Promoter, for additional information necessary in relation to the Event for which you are buying tickets (e.g. for health and safety requirements).

      WEBSITE USE

      We log your visits and use of our Service, your usage data when you visit or otherwise use our Service. We use log-ins, IP addresses, cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to log your use and identify you or your device. Please read our Cookies Policy to learn more about how we use cookies and similar tracking technologies and how to opt out.

      When you visit or leave our Site, we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Site from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we respect your settings.

    5. HOW WE USE YOUR PERSONAL DATA

      We use Personal Data of our users to give them access to our Site and to provide them withinour Service and in particular to:

      • a. administer and process registrations and/or purchases;
      • b. authenticate users and grant users with access to some areas of our Site;
      • c. correspond with users through any Communication Methods, about their registration and/or purchases;
      • d. contact users via any Communication Methods about the availability of our services, security, other service-related issues, network updates, reminders, and suggestions;,
      • e. provide users with information about WAPPA products and services, provided that you have opt-in to receiving our marketing communications. You may opt to be excluded from communications regarding WAPPA and our products and services by ticking the appropriate box in the Registration Section upon creating an account, by ticking the appropriate box in your Customer Account or by sending an email to [email protected].;
      • f. produce aggregate insights that do not identify any individual user of our Service; and
      • g. investigate, respond to and resolve complaints and service issues. Please be aware that as long as you are using our Service you cannot opt out of receiving essential service messages from us, including security and legal notices.
    6. RECIPIENTS OF YOUR DATA

      PROMOTERS

      We share your name with the Promoter responsible for organising the Event for which you are purchasing tickets through our Service (Relevant Promoter). If, upon registration on while using our Service, you have opted-in to receiving marketing emails from a specific Promoter, we will share your name, email address, DOB, and address with such Promoter.

      Q-FLOW

      If you have not opted-in to receiving marketing emails from us and/or from the Relevant Promoter, we may share your name with Q-Flow (a company providing a ticket scanning and smart guest list app, http://www.getqflow.com/) if the Relevant Promoter use their services.

      If you have opted-in to receiving marketing emails from us and/or from the Relevant Promoter, we will share your email address with Q-Flow.

      MAILCHIMP

      If you have opted-in to receiving marketing emails from us and/or from the Relevant Promoter, we will share your email address with Mailchimp (a marketing automation platform, https://mailchimp.com/).

      If a customer ‘opts in’ of sharing their email address for marketing, we would share their name, email address, DOB, postcode with the Promoter they bought a ticket for (we don’t pass it on to any other Promoters), we also save it in our Mailchimp account. Their email address may also be saved in Q-flow. Our merchant partners have access to their name, card details, and their address.

      WIRECARD AND PAYPAL

      We will share with Wirecard (a payment service provider, https://www.wirecard.com/) and Paypal (a payment service provider, https://www.paypal.com/gb/home) the name, card details, and address of the person making the payment.

      ADDITIONAL DISCLOSURES

      To provide and develop our Service, we may also share your Personal Data with:

      • a. our subsidiaries, as defined by section 1162 of the Company Act 2006 as amended, extended or re-enacted from time to time, provided that our subsidiaries will be subject to the same terms of this Privacy Policy;
      • b. subcontractors who may perform the whole or part of the Services on behalf of WAPPA (“Subcontractors”), provided that the Subcontractors will be bound to substantially the same obligations imposed on WAPPA under its agreement with each Data Controller for the time being and to the terms of this Privacy Policy; and
      • c. third parties (e.g. for maintenance, analysis, audit, payments, marketing and development). Third parties will only have access and use your information as reasonably necessary to perform these tasks on our behalf and they will be bound to non-disclosure obligations and to the terms of this Privacy Policy.

      We may have to disclose your Personal Data if it is reasonably necessary to: (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you; (iii) investigate and defend ourselves against any third-party claims or allegations; (vi) protect the security or integrity of our Services.

      We will attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.

      We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not undertake or warrant to challenge every demand.

      We may also share your Personal Data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys WAPPA or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.

    7. DATA RETENTION

      Unless you have agreed for us to retain your Personal Data for a longer period, we will keep your Personal Data only for as long as it is necessary to provide you with our Service.

      We may need to retain part of your Personal Data even after termination of this agreement with you, if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our agreements with you.

    8. CROSS-BORDER DATA TRANSFERS

      Except if necessary to provide you with the Service (e.g. if a Promoter is based outside the EEA), we do not transfer, store or process your Personal Data at destinations outside the EEA.

      Even if it is necessary to provide you with the Service, we will always ask for your consent before transferring your Personal Data outside the EEA.

    1. GENERAL

    2. CHANGE TO THIS PRIVACY POLICY

      As we are committed to constantly improving our Service, we may change the selection of data and the way we process it. We reserve the right to change or adapt this Privacy Policy from time to time. In case of any material change to our Privacy Policy, we will update the version available on our Site as soon as reasonably possible.

    3. LINKING TO OTHER WEBSITES

      For your information and convenience only, the Site contains hyperlinks to Third-Party Websites. WAPPA has no control over and does not endorse any content or service displayed, contained or related to those Third-Party Websites. We make no warranties or representations, express or implied, about Third-Party Websites or any content, products, material or service contained, displayed or related to them. If you decide to access any Third-Party Websites and make use of the information contained on them or to enter into any contract for the supply of goods or services from such third party, you do so entirely at your own risk. We accept no liability for damage or loss, however caused in the connection with the use of or reliance on any information, material, products or services contained on or accessed through any such Third-Parties Websites.

    4. THIRD-PARTY ADVERTISERS

      We do not share your Personal Data with any third-party advertisers or ad networks for their advertising without your separate permission.

    5. MARKETING

      We do not send you marketing communications unless you have opted-in to receiving our and/or Promoters marketing communications.

      You can opt-out at any time by changing your preferences in your Ticket Tannoy account. To change your marketing references, you may also email us at: [email protected]

    6. SECURITY

      We implement a number of security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

    7. YOUR RIGHTS

      RIGHT OF ACCESS

      We offer you access to the Personal Data we hold about you. Please be aware that the purpose of an access request is to give you the opportunity to confirm the accuracy of Personal Data we are holding about you, the lawfulness of our processing and to allow you to exercise your rights under Applicable Data Protection Laws if necessary.

      We reserve the right to reject manifestly unfounded (e.g. made for other, non-data protection purposes) or excessive requests.

      To have access to the Personal Data we store about you, please contact us at: [email protected].

      RIGHT TO WITHDRAW CONSENT

      Please be aware that, if you have given us consent to process your data for the purposes detailed in this Privacy Policy, you can always change your mind and withdraw your consent by contacting us at [email protected].

      In order to process your request, we may ask you to send us a copy of two forms of identification (such as passport, driving licence, birth certificate, bank statement, utility bills).

      FURTHER RIGHTS

      You also have the right to lodge a complaint about our processing of your data and/or our handling of your complaints to ICO or the appropriate data protection authority if you reside outside the United Kingdom.

      To learn more about your rights please visit ICO’s website at https://ico.org.uk/.