Last Updated: January 18, 2023
In operating the Services, we collect certain information from and about you to enable us to automate and manage various tasks relating to your business, and to improve the Services.
Before you use or submit any information through or in connection with the Services, please carefully review this Policy. By using any part of the Services or otherwise providing us with information subject to this Policy, you understand that your information will be collected, used, and disclosed as outlined in this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES OR OTHERWISE PROVIDE US INFORMATION.
This Policy contains the following sections:
1. Information We Collect
2. How We Use Your Information
3. When We Disclose Your Information
4. Your Choices and Rights
5. International Transfers
7. Data Retention
8. Third-Party Links and Services
9. Changes to this Policy
10. Children’s Privacy
11. Questions About this Policy
12. Regional Privacy Notices and Rights
1. Information We Collect
We collect information in multiple ways, including when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties.
a. Information You Provide Directly to Us
We will collect any information that you provide to us. For example, if you create an online account, contact us for information or for customer support, or otherwise submit information through the Services, we will collect details such as your name, email address, phone number, and mailing address.
When a transaction is submitted through the Services, we collect certain details of the transaction that are needed to create and/or manage listings on retail ticket marketplaces and to properly process the transaction. Such details include, but are not limited to, sales information
(e.g., event, venue, event date and time, quantity of tickets, section, row, seat numbers, sales price, etc.) and transaction date and time. For each such transaction you submit to us for processing, our Services may also collect and store authentication tokens, the marketplace, and an order identification.
b. Information that Is Automatically Collected
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, and mobile device carrier information; and (b) information related to the ways in which you interact with the Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c) understand the web pages of the Services you have visited; (d), enhance your user
experience by delivering content and advertisements specific to your inferred interests; (e) perform searches and analytics; and (f) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information. We also may include web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics and personalization. As we adopt additional technologies, we may also gather additional information through other methods.
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
c. Information from Third Parties
We may also collect information about you from third parties, including public sources, partners, and marketers.
2. How We Use Your Information
We may use the information we collect from and about you for the following purposes:
• To create your account, process transactions, and facilitate your use of the Services; • To provide and improve the Services, including to develop new features or services, to take steps to secure the Services, and for technical and customer support; • To send you information about your relationship or transactions with us, account alerts, or other important updates or communications;
• For marketing and advertising purposes, including to contact you with information or surveys that we believe may be of interest to you both regarding our products and Services and those of third parties;
• To tailor content to you, such as to tailor the properties we contact you about based on our perception of your interest through your use of the Services;
• To process and respond to your inquiries or to request your feedback; • For analytics, research, and reporting, including to synthesize and derive insights from your use of our Services;
• For internal administrative purposes, such as taking steps to secure the Services; • To comply with the law and protect the safety, rights, property, or security of us, the Services, and the general public; and
Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Services. Such aggregated and/or de-identified data may include, without limitation, data derived from the listing and/or sale of our clients’ tickets via the Services, but which no longer identifies specific clients or any individual person (e.g., event name, date, venue, seat location, ticket price, date of sale, and retailer where the sale occurred). We may use aggregated and/or de-identified data for any purpose, including without limitation for research and marketing purposes.
3. When We Disclose Your Information
We may disclose your information under the following circumstances:
• Service Providers. We may disclose your information to third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, data analysis and processing, and legal services.
• Legal Compliance and Protection of TEVO and Others. We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Policy or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce this Policy, or other contracts
with you, including investigation of potential violations thereof; (c) to respond to your requests for customer service; and/or (d) to protect the rights, property, or personal safety of TEVO, our agents and affiliates, our customers, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
• Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of TEVO’s assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
• Affiliated Companies. We may disclose your information with current or future affiliated companies.
• Consent. We may disclose your information to any third parties based on your consent to do so.
• De-identified / Aggregated Data. We may disclose de-identified and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others without limitation.
4. Your Choices and Rights
You can unsubscribe from marketing emails by clicking the "unsubscribe" link they contain. If you have registered for an account with us through our Services, you can also update certain information by logging into your account and updating your account information and communications settings.
Residents of California, the European Economic Area, and the United Kingdom have certain legal rights. Please review the Regional Privacy Notices and Rights section below for more information.
5. International Transfers
Our systems are currently based in the United States, and your information will be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction. For example, data may be accessible to law enforcement and national security authorities under certain circumstances. As explained herein, we may also subcontract the processing of your data to, or otherwise disclose your data to service providers, and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or
disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
7. Data Retention
We will retain your information for as long as necessary to fulfill the purposes set forth in this Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
8. Third-Party Links and Services
The Services may contain links to third party websites, applications, and other services that are not controlled or operated by TEVO. This Policy does not apply to such third parties, and TEVO is not responsible for the privacy practices of the third parties. For that reason, TEVO encourages you to request and review the privacy policies applicable to any third party before you disclose information to those third parties.
9. Changes to this Policy
We will continue to evaluate this Policy as we update and expand our Services, and we may make changes to the Policy accordingly. Any changes will be posted here, along with an updated “effective date” at the top of the document, and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.
The Services are not intended for children under the age of 18. Moreover, TEVO does not knowingly collect “personal information” (as defined in the Children’s Online Privacy Protection Act or “COPPA”) from children under the age of 13. If TEVO becomes aware that it has collected personal information from children under the age of 13, TEVO will take steps to delete such information in accordance with its legal obligations.
11.Questions About this Policy
TEVO welcomes questions and comments about this Policy and our practices. Please feel free to contact us via email at email@example.com, firstname.lastname@example.org or email@example.com, or by mail at:
Ticket Evolution Inc.
Attn: General Counsel
2788 S. Arlington Mill Dr., Suite 275
Arlington, VA 22206
12.Regional Privacy Notices and Rights
a. Residents of the European Economic Area and the United Kingdom
The laws in the European Economic Area and the United Kingdom (collectively, the “EU”) require companies to tell you about the legal ground they rely on to use or disclose information that can be directly linked to or used to identify you. To the extent those laws apply, i.e. where
we are the data “controller” of your personal data, our legal grounds for processing such information are as follows:
• To Honor Our Contractual Commitments to You. Much of our processing of information is to meet our contractual obligations to provide products and services to our users and customers.
• Legitimate Interests. In many cases, we handle information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
o Customer service
o Marketing and advertising
o Protecting our users, personnel, and property
o Analyzing and improving our business
o Managing legal issues
• Legal Compliance. We need to use and disclose information in certain ways to comply with our legal obligations.
• Consent. Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent.
Laws of the EU permit you request that we:
• provide access to and/or a copy of certain information we hold about you; • prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling)
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information; • transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information, without affecting the lawfulness of processing based on consent before its withdrawal.
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To exercise these rights, please email us at firstname.lastname@example.org or email@example.com with the nature of your request. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
If you are located in the EU and we provide any information about you to non-EU members of our group or third party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data.
b. Residents of California
The California Consumer Privacy Act (“CCPA”) requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we disclose personal information.
Throughout this Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we share it. Under the CCPA, we also have to provide you with the "categories" of personal information and sensitive personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by applicable law). The categories of personal information are identifiers (such as name, mailing address, and email address); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address); professional or employment related information (such as your current employer); inference data about you; audio and visual information (such as when you call into customer service or visit our offices), and other information that identifies or can be reasonably associated with you. The categories of sensitive personal information are account log-in and password or other credentials allowing access to your account.
We (directly or through service providers) collect and disclose the above categories of personal information for the purposes described in our Policy. This includes the following business and commercial purposes (as those terms are defined in the CCPA):
• Provide the Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communication about the Services);
• Operational purposes (e.g. to enable and troubleshoot our Services);
• Auditing consumer interactions on our site (e.g., measuring ad impressions); • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection, error reporting, and activities to maintain the quality or safety of our Services;
• Short-term, transient use, such as customizing content that we or our service providers display on the Services;
• Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third-party advertising;
• Other uses about which we notify you.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; (3) affiliates; and (4) third parties such as public sources, partners, and marketers.
We describe our information disclosure practices in Section 3 above.
We may combine the information we collect (“aggregate”) or remove pieces of information (“de identify”) to limit or prevent identification of any particular user or device. We may use or disclose this aggregated or de-identified information in our discretion.
California consumers may have certain rights. California law may permit you to request that we:
• Provide you with the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell” or “share.
• Provide access to and/or a copy of certain information we hold about you. • Delete certain information we have about you.
• Correct inaccurate personal information that we maintain about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.
If you would like to exercise any of these rights, please email us at firstname.lastname@example.org or email@example.com with the nature of your request. You may also call us at [**INSERT TOLL-FREE NUMBER]. You will be required to verify your identity before we fulfill your request. To do so, you will need to provide the information requested by us. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
“Sale” and “sharing” of personal information. The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. We do not engage in such activity based on our understanding of the definitions of “sale” and “sharing” under the CCPA and current guidance. Since we do not “sell” or “share” personal information, we also do not knowingly “sell” or “share” the personal information of children under 16.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
Retention of Your Personal Information. Please see the “Data Retention” section above.
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.
California law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes. However, we do not disclose your personal information with third parties for their own direct marketing purposes.