atVenu, Inc. (“atVenu”), respect your concerns about privacy. atVenu participates in the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF (“UK Extension”) (collectively, the “Data Privacy Framework” or“DPF”) administered by the U.S. Department of Commerce. atVenu commits to comply with the DPF Principles with respect to Consumer Personal Data the company receives from the EU and UK in connection with atVenu’s services. If there is any conflict between the terms in this Privacy Policy (“Policy”) and the DPF Principles, the DPF Principles shall govern.
For purposes of this Policy:
“Consumer” means any natural person who is located in the EU or UK, but excludes any individual acting in his or her capacity as an Employee.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“DPF Principles” means the Principles and Supplemental Principles of the DPF.
“EU” means the European Union and Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by atVenu in the U.S. from the EU or UK, (iii) recorded in any form, and (iv) obtained by atVenu in connection with atVenu Services.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
“atVenu Services” means atVenu’s proprietary payment platform services for EU or UK customers that are performed at various events and venues for servicing of customers’ end user (‘fans’ or “Consumers”) at such events pursuant to written agreements with atVenu customers.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).
“UK” means the United Kingdom.
atVenu’s DPF certification, along with additional information about theDPF, can be found at
https://www.dataprivacyframework.gov/. For more information about atVenu’s processing of Consumer Personal Data the company obtains through atVenu Services, please visit the atVenu Privacy Policy (https://www.atVenu.com/privacy-policy).
Types of Personal Data atVenu Collects
atVenu collects Personal Data directly from Consumers when they use atVenu Services. The company may use this information for the purposes described in the atVenu Privacy Policy (https://www.atVenu.com/privacy-policy).
The types of Personal Data atVenu collects from Consumers when they use atVenu Services include:
● Information by which you may be personally identified, such as first and last name, postal address (if necessary), email address, telephone number and any other identifier by which you may be contacted online or offline;
● Information that is about you but individually does not identify you, such as user names, avatar information or other pseudonyms that you may use; and/or
● Information about your internet connection, the equipment you use to access our Website, and usage details.
atVenu also may obtain and use Consumer Personal Data in other ways for which the company provides specific notice at the time of collection.
atVenu’s privacy practices regarding the processing of Consumer Personal Data comply with the DPF Principles of Notice; Choice; Accountability forOnward Transfer; Security; Data Integrity and Purpose Limitation; Access; andRecourse, Enforcement and Liability.
Notice
atVenu provides information in this Policy, the atVenu Privacy Policy (https://www.atVenu.com/privacy-policy) about its ConsumerPersonal Data practices, including the types of Personal Data atVenu collects, the types of third parties to which atVenu discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data and how to contact atVenu about its practices concerning Personal Data.Relevant information also may be found in notices pertaining to specific data processing activities.
Choice
atVenu generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the DPF Principles, atVenu obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact atVenu as indicated below regarding the company’s use or disclosure of their Personal Data. Unless atVenu offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
atVenu shares Consumer Personal Data with its affiliates and subsidiaries. atVenu may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions if requested by Consumers or atVenu’s customers, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. atVenu also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
Accountability for Onward Transfer of Personal Data
This Policy and the atVenu Privacy Policy (https://www.atVenu.com/privacy-policy) describe atVenu’s sharing of Consumer Personal Data.
Except as permitted or required by applicable law, atVenu provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. atVenu requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process thePersonal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the DPF Principles, and (iii) notify atVenu and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the DPF Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, atVenu (i) enters into a contract with each relevant Processor,(ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with atVenu’s obligations under the DPF Principles, (v) requires the Processor to notify atVenu if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. atVenu remains liable under the DPF Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the DPF Principles, unless atVenu proves that it is not responsible for the event giving rise to the damage.
Security
atVenu takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.
Data Integrity and Purpose Limitation
atVenu limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. atVenu does not processConsumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, atVenu takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, atVenu relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact atVenu as indicated below to request that atVenu update or correct relevant Personal Data.
Subject to applicable law, atVenu retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which thePersonal Data was collected or subsequently authorized by the Consumer.
Access
Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, atVenu provides Consumers with reasonable access to the Personal Data atVenu maintains about them. atVenu also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. atVenu may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting atVenu as indicated below.
Jurisdiction
The Federal Trade Commission has jurisdiction over atVenu’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.
Recourse, Enforcement and Liability
atVenu has mechanisms in place designed to help assure compliance with the DPF Principles. atVenu conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions atVenu makes about its DPF privacy practices are true and that atVenu’s privacy practices have been implemented as represented and in accordance with the DPF Principles.
Consumers may file a complaint concerning atVenu’s processing of their Personal Data. atVenu will take steps to remedy issues arising out of its alleged failure to comply with the DPF Principles. Consumers may contact atVenu as specified below about complaints regarding atVenu’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through atVenu’s internal processes, atVenu will refer the dispute to either the EU Data Protection Authorities (DPAs) or the UK Information Commissioner’s Office (ICO) as applicable.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S.DPF, atVenu commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S.DPF and the UK Extension to the EU-U.S. DPF.
Binding Arbitration
Under certain conditions you may be eligible to invoke binding arbitration. atVenu may be obligated to arbitrate claims and follow the terms set forth in Annex I of the EU-U.S. and UK Extension DPF Principles, provided that you deliver a notice to atVenu and following the procedures set forth in Annex I of the DPF Principles.
How to Contact atVenu
To contact atVenu with questions or concerns about this Policy or atVenu’s Consumer Personal Data practices:
Write to:
atVenu, Inc.
927 Calle Negocio
Suite J
San Clemente, CA 92672
Or email us at:
atvenu1@bearflagservices.zohodesk.com
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