Privacy Policy

Introduction

Welcome to the privacy policy (“ Privacy Policy ”) of Citizen Ticket Ltd (“ Citizen Ticket ”, “ we ” or “ our ”).

Throughout this Privacy Policy, any reference to “ Organiser ” shall mean event organisers using our Platform (as defined below) to sell tickets to their events, and any reference to “ Consumer ” shall mean consumers using our Platform (as defined below) to purchase tickets from Organiser, attend, or obtain information about, events, or for other purposes. Organisers, Consumers and any persons to whom this Privacy Policy applies, shall be collectively referred to as “ you ” or “ your ”.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit and interact with our website, our Ticket Wallet app and/or our Organiser Toolbox app (collectively, the “ Platform ”), regardless of where you visit it from, or when your personal data is otherwise collected through our provision of products and services, and tell you about your privacy rights and how the law protects you.

Citizen Ticket Ltd is committed to creating best-in-class ticketing, accreditation, and access control software that is loved by festivals and experiences globally. Protecting your personal data is central to this mission. This Privacy Policy explains how we collect, use, and protect your personal data. It also explains your rights under data protection law. It's important to understand that sometimes we process your data for our own purposes (as a 'data controller'), and sometimes we process it on behalf of Event Organisers (as a 'data processor'). We'll explain these roles more clearly throughout this policy.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1 IMPORTANT INFORMATION AND WHO WE ARE

2 THE DATA WE COLLECT ABOUT YOU

3 HOW IS YOUR PERSONAL DATA COLLECTED?

4 HOW WE USE YOUR PERSONAL DATA

5 DISCLOSURES OF YOUR PERSONAL DATA

6 INTERNATIONAL TRANSFERS

7 DATA SECURITY

8 DATA RETENTION

9 YOUR LEGAL RIGHTS

10 GLOSSARY

IMPORTANT INFORMATION AND WHO WE ARE
1. Purpose of this Privacy Policy
  1. This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Platform (including any data you may provide through the Platform as detailed in paragraph 3.1 below) and through our provision of products and/or services.
  2. The Platform is not intended for children under the age of 16. We do not knowingly collect data relating to children under such age.
  3. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
2. Our Roles: Data Controller and Data Processor
  1. Citizen Ticket Ltd acts in different roles depending on how your personal data is being used:
    1. When you interact directly with Citizen Ticket Ltd for our own services: For example, if you create a general Citizen Ticket account with us (not just for one event), subscribe to our newsletters, or if we process your data as an employee or supplier, Citizen Ticket Ltd is the Data Controller. This means we decide why and how your personal data is processed.
    2. When you purchase tickets for an event or interact with an event organised by an Event Organiser using our Platform: In most cases, the Event Organiser is the Data Controller for the personal data you provide for that event (e.g., your name, contact details for the ticket, any specific event requirements). Citizen Ticket Ltd acts as a Data Processor in these situations, meaning we process your data on behalf of and according to the instructions of the Event Organiser. The Event Organiser's own privacy policy will also apply, and we encourage you to read it.
    3. Joint Controller Situations: In some limited circumstances, such as when we analyse aggregated and anonymised sales data for platform improvement or industry insights, Citizen Ticket Ltd might act as a Joint Controller with Event Organisers. Where this happens, we will ensure there is a clear agreement in place outlining our respective responsibilities.
  2. This Privacy Policy primarily covers how Citizen Ticket Ltd processes personal data when we are the Data Controller. When we act as a Data Processor for an Event Organiser, we do so under their instruction and their privacy policy will provide further details.
  3. We have a data protection team which is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our data protection team using the details found under "Contacting Us About Data Protection" in this policy.
3. Contacting Us About Data Protection
  
  Citizen Ticket Ltd is responsible for your personal data when we act as the Data Controller. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy and our compliance with data protection laws. If you have any questions about this Privacy Policy, how we handle your data, or wish to exercise your legal rights (see section 9), please contact our Data Protection Officer:
  
  Full name of legal entity: Citizen Ticket Ltd
  
  Email address: info@citizenticket.co.uk
  
  Postal address: 63 Dublin Street, Edinburgh, EH3 6NS
4. Changes to the Privacy Policy and your duty to inform us of changes
  1. We keep our Privacy Policy under regular review.
  2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. Third-party links
  1. The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Platform, we encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU
1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. As further detailed in the table at paragraph 4.4, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. “ Identity Data ” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  2. “ Contact Data ” includes billing address, delivery address, email address, social media handles and telephone numbers.
  3. “ Financial Data ” includes bank account and payment card details.
  4. “ Transaction Data ” includes details about payments to and from you and other details of products and services you have purchased from us or other transactions between you and us.
  5. “ Technical Data ” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, full uniform resource locator (URL) clickstream to, through and from the Platform (including date and time) and other technology on the devices you use to access the Platform.
  6. “ Profile Data ” includes your username and password, purchases or orders made by you, your interests, preferences, relationships held with other data subjects, feedback and survey responses, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
  7. “ User Generated Content ” includes any content generated by you or otherwise belonging to you, which is used, with your express consent, in your interaction with the Platform, such as photos, videos and audio data.
  8. “ Usage Data ” includes information about how you use the Platform, products and services.
  9. “ Marketing and Communications Data ” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3. As further detailed in the table at paragraph 4.4, we also collect, use and share “ Aggregated Data ” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly relate to an identified or identifiable living individual. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
4. As further detailed in the table at paragraph 4.4, we may also collect personal data that includes “ Sensitive Data ” (also known as “ Special Category Data ”), such as certain health and medical information (including where required to ensure a safe environment and adherence to government instructions and guidelines).
5. If you fail to provide personal data
  1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
1. We use different methods to collect data from and about you including through:
  1. Direct interactions . You may give us your personal data (in those categories listed above) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    1. apply for and/or purchase our products or services;
    2. contact us and/or sign up to hear from us via email, phone, video call or otherwise;
    3. create an account on the Platform (including Organiser Profiles);
    4. subscribe to our service or publications;
    5. request marketing to be sent to you;
    6. apply for and/or purchase tickets;
    7. enter a competition, promotion or survey;
    8. give us feedback; or
    9. otherwise submit information on the Platform.
  2. Automated technologies or interactions . As you interact with the Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  3. Third parties or publicly available sources . We may receive personal data about you from various third parties and public sources, such as:
    1. Event Organisers (if you are a Consumer), analytics providers, advertising networks, search information providers, sub-contractors and providers of technical, payment, delivery, back-up and data storage services, credit reference agencies, data brokers or aggregators;
    2. third parties to whom you have provided personal information that you have elected to transfer to us; and
    3. publicly available sources, such as Companies House and the Electoral Register based within the UK.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1. where we need to perform a contract we are about to enter into or have entered into with you;
2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
3. where we need to comply with a legal obligation.
Please refer to the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message, or filming and photography at any event organised by Citizen Ticket. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
1. We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. In carrying out each activity, we may process your data for a number of different purposes. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
3. Where Sensitive (Special Category) Data is processed, such as health information for accessibility, this is typically done on behalf of the Event Organiser (who is the Data Controller for this purpose) based on your explicit consent given to them, or another specific condition under Article 9 of the UK GDPR. Citizen Ticket acts as a Data Processor in such instances. If Citizen Ticket collects such data as a Controller, we will ensure a specific Article 9 condition applies and is communicated to you.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer (through creation of an account on the Platform)	Identity Contact Profile Usage Technical Marketing and communications	Performance of Contract with you Necessary for Our Legitimate Interests (to facilitate your registration with Citizen Ticket, to keep our customer records up-to-date and to study how customers use our Platform) To contact you about news and information regarding the events for which you have purchased tickets (if you are a Consumer), and any other offerings which we feel may be of interest to you based on your previous interaction or preferences
To enable you to use, or otherwise interact on, the Platform	Identity Contact Profile User Generated Content Usage Technical Marketing and Communications	Performance of Contract with you Necessary for Our Legitimate Interests (to deliver our services to you and to study how customers use our Platform) To contact you about news and information regarding the events for which you have purchased tickets, and any other offerings which we feel may be of interest to you based on your previous interaction or preferences
To manage, process and/or deliver your order including: Managing payments, fees and charges Processing refunds Collecting and recovering money owed to us Enabling transfers of tickets purchased (if applicable)	Identity Contact Financial Transaction User Generated Content (such as photos and videos uploaded via our ID Feature, “Citizen Identity”) Marketing and Communications	Performance of Contract with you Necessary for our Legitimate Interests (to keep our records updated and to recover debts due to us)
To enable you to attend any event organised by any Organiser or Citizen Ticket, with the aim of: creating a safe environment (including observing protocols around limiting the number of visitors and staff within our spaces, wearing face coverings and installing signage, to ensure any social distancing measures are observed) adhering to the most up-to-date government instructions and guidelines maintaining and monitoring facilities for health and safety purposes	Identity Contact Sensitive	Necessary to Comply with a Legal Obligation Necessary for our Legitimate Interests (to keep our records updated and to assess your ongoing qualification to attend any events)
To facilitate entry management of any event organised by Organiser or Citizen Ticket (some of which may require identity verification)	Identity User Generated Content (such as photos and videos uploaded via our ID Feature, “Citizen Identity”)	Performance of Contract with you Necessary for our Legitimate Interests (to keep our records updated and to assess your ongoing qualification to attend any events)
To enable you to be a partner, sponsor or supplier or potential partner, sponsor or supplier of, or to, us or our events	Identity Contact Financial Transaction Marketing and Communications	Performance of Contract with you (as our partner, sponsor or supplier) Necessary for our Legitimate Interests (We need this data to be able to contact you about becoming a partner, sponsor or supplier to allow you to become officially associated with us or our event(s)) Necessary to Comply with a Legal Obligation (including for tax purposes)
To manage our relationship with you which will include: Notifying you about changes to the Platform, any of our terms or Privacy Policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of Contract with you Necessary to Comply with a legal obligation Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of Contract with you Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business)
To televise, film and/or otherwise record our events and to take photographs and record footage of our events	Identity	Your consent Necessary for our Legitimate Interests (We need the ability to publish, display, sell and distribute our events by means of film, television, radio, print media, internet, publicity material or any other media now or in the future)
To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to Comply with a legal obligation
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services (which may be third-party related) that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Your explicit consent Necessary for our Legitimate Interests (to develop our products/services and grow our business)
To enable you to attend any event organised by any Organiser or Citizen Ticket, with the aim of: creating a safe environment/adhering to government instructions/maintaining and monitoring facilities for health and safety purpose	Sensitive	Necessary to Comply with a Legal Obligation

Marketing
1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
1. We will get your express opt-in consent before we use your Identity Data, Contact Data, Technical Data, Usage Data and/or Profile Data to contact you about goods or services that may be of interest to you (we call this marketing).
Third-party marketing
1. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
2. For the avoidance of doubt, should any personal data be shared with any third party (such as Organisers, if you are a Consumer) in accordance with paragraph 4.7.1 above, the privacy policy of the relevant third party shall apply to any such shared personal data.
Opting out
1. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, following the opt-out links on any marketing message sent to you or by contacting us.
2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a ticket/product/service purchase, event/product/service experience or other transactions.
3. For other processing activities based on consent, you can withdraw your consent by contacting our Data Protection Officer.
Cookies
1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .
Change of purpose
1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA
1. We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.4 above:
  1. Internal Third Parties as set out in the Glossary;
  2. External Third Parties as set out in the Glossary; and
  3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or their assets or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
3. Please note that when you purchase a ticket from an Event Organiser, the Event Organiser is the Data Controller and may have their own arrangements for sharing your data with other third parties necessary for the event (e.g., venue, other service providers for the event). These disclosures will be governed by the Event Organiser's privacy policy.
INTERNATIONAL TRANSFERS
1. Generally, we aim to store and process your personal data within the UK. However, some of our third-party service providers may be based outside the UK, or use data centres located outside the UK. If we do transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK authorities.
  2. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (such as the UK Addendum to the EU Standard Contractual Clauses). Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
DATA SECURITY
1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Further details on our security practices are outlined in our internal Security Policy, which all our staff must adhere to.
2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION

How long will you use my personal data for?
1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. 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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
3. Specific retention periods for different types of data are defined in our internal Secure Disposal Policy. When acting as a Data Processor for an Event Organiser, we will retain data according to their instructions and our contractual agreement with them.
4. By law we generally have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. The six years run from the end of the company financial year to which the customer records relate.
5. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
6. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
1. Under data protection law, you have several rights in relation to your personal data when Citizen Ticket acts as the Data Controller. When we act as a Data Processor for an Event Organiser, you should typically direct requests to exercise your rights to the Event Organiser, but we will assist them as required. Your rights include:
  1. Request access to your personal data.
  2. Request correction of your personal data.
  3. Request erasure of your personal data.
  4. Object to processing of your personal data.
  5. Request restriction of processing your personal data.
  6. Request transfer of your personal data.
  7. Right to withdraw consent.
2. If you wish to exercise any of the rights set out above, please indicate so via your account settings on the Platform or contact us.
3. No fee usually required
  1. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
4. What we may need from you
  1. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
5. Time limit to respond
  1. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month taking into account the complexity and number of requests. In this case, we will notify you and keep you updated.
YOUR RIGHT TO LODGE A COMPLAINT
1. We are committed to resolving any concerns you may have about our use of your personal data. If you have any complaints, we encourage you to contact our Data Protection Officer (DPO) using the details provided in Section 1, so that we can address your concerns.
2. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you are unhappy with how we have used your data or handled your rights. The ICO is the UK's independent body set up to uphold information rights. You can contact the ICO through their website: www.ico.org.uk Or by calling their helpline: 0303 123 1113 Information Commissioner's Office Wycliffe House, Water Lane Wilmslow, Cheshire SK9 5AF
GLOSSARY
1. Lawful Basis
  1. “ Legitimate Interest ” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. This may involve processing for purposes of direct marketing, fraud prevention and ensuring network and information security (including prevention of unauthorised access to electronic communications networks, malicious code distribution, ‘denial of service’ attacks and damage to computer and electronic communication systems). We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. Where we rely on the legitimate interest basis to process your personal data, we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  2. “ Performance of Contract ” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  3. “ Comply with a legal obligation ” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
2. Third Parties
  1. Internal Third Parties
    
    Any other entity within our group from time to time, acting as joint controllers.
  2. External Third Parties
    1. Business partners, Event Organisers (if you are a Consumer), suppliers and sub-contractors for the performance of any contract we enter into with them or you;
    2. Service providers who provide IT and system administration services;
    3. Analytics and search engine providers that assist us in the improvement and optimisation of the Platform;
    4. Professional advisers, including lawyers, bankers, auditors and insurers who use your personal data to provide consultancy, banking, legal, insurance and accounting services to us;
    5. HM Revenue & Customs based in the United Kingdom, regulators and other authorities (whether national or international) who use your personal data and require reporting of our processing activities in certain circumstances; and
    6. Any other third party in the event that we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, including exchanging information with other companies and organisations for the purposes of fraud protection and credit reduction.
  3. Your Legal Rights
    You have the right to:

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