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Privacy Policy

LAST UPDATED 4 NOVEMBER 2020

ABOUT US

We, Pollen (which is the trading name of StreetTeam Software Limited, a limited liability company with registered number 09750608 and its registered office at 3 Loughborough Street, SE11 5RB, London) (referred to as Pollen, we, us and our) respect your privacy and we are committed to protecting your personal data.

We operate certain subdomains located at pollen.co and the corresponding mobile applications (together and separately, the Service) that enable a consumer (Customer) to purchase tickets, vouchers and other related services (together, Tickets) and related merchandise (Merchandise) for events organized by participating third parties (Event Organizers), promoted by persons authorized by us (Members) and using links to the Sales Platform provided to the Members by us (Links).

This privacy policy (Privacy Policy) will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how Pollen collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a Ticket and/or Merchandise.

This website is not intended for children and we do not knowingly collect data relating to children.

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.

This Privacy Policy applies to both Members and Customers, and all other visitors to our website.

This Privacy Policy is incorporated into our Member Terms of Service and Customer Terms of Service.

CONTROLLER  

Pollen is the controller and responsible for your personal data.

We have appointed a data privacy manager who 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 the  data privacy manager using the details set out below.

CONTACT DETAILS  

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: StreetTeam Software Limited

Email address: legal@pollen.co

Postal address: 3 Loughborough Street, SE11 5RB, London, UK

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may occasionally update this Privacy Policy.

Whenever we update this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy.

Please ensure that you frequently check this Privacy Policy for any updates.

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.

THIRD PARTY LINKS

This website 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 our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier and date of birth.

• Contact Data includes delivery address, email address, social media handles and telephone numbers.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• 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, and other technology on the devices you use to access this website.

• Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

As a Member of Pollen, we will collect information about you regarding your role as a Member and the events, campaigns and rewards related to your activities as a Member.

As a Customer purchasing a Ticket and/or Merchandise through our Services, we will collect information about you in order for us to fulfil your purchase.

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 reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

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 a Ticket and/or Merchandise that you have purchased). In this case, we may have to cancel the contract but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide if you:

• apply to become a Member;

• create an account on our website;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, 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. Please see our Cookies Policy for further details.

HOW DO 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:

•   Where we need to perform the contract we are about to enter into or have entered into with you.

•   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.

•   Where we need to comply with a legal obligation.

Below we set out the types of lawful basis that we will rely on to process your personal data:

  • 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. 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. 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.
  • 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.
  • 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.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We may use the personal data you provide to us to:

  • provide you with those tickets, goods, and services which you have requested through our Service;
  • provide you with personalised visits to our Service;
  • share your personal data with our partners (detailed below);
  • recommend future events, goods, and services which may be of interest to you (but only where you have consented to be contacted for such purposes);
  • recommend a role for you if a suitable opportunity arises (but only where you have consented to be contacted for such purposes);
  • develop our offers and the structure of our Service to ensure that our services are as useful and enjoyable as possible;
  • to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • contact you (including by text message for account-related messages, if you have provided your mobile phone number); and
  • send out any email alerts that you may have signed up for.


OPTING OUT
 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Ticket/Merchandise purchase.

COOKIES  

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

CHANGE OF PURPOSE  

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.

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.

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.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal data with the parties set out below.

We will share your personal data with organisers of events for which you have purchased tickets, goods or services in order to ensure their delivery (“Vendors”).  We will only ever share your personal data with Vendors for marketing purposes if you have consented to us doing so.  Members may update their “Settings” in their Member Account any time.

We may also share any information that we receive through the Service with vendors and service providers retained in connection with the provision of the Service, including for data analytics purposes. One of the service providers that we use for data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of the Services, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) to opt out across all websites. Alternatively if you are a Member, you can opt out in the settings area of your Member account, or as a customer you can opt-out by following the appropriate link in your email communications from us. Should you have any trouble you may contact us at support@pollen.co.

We may also share your information with third parties in the following situations, to the extent permitted by law:

  • with various data processors such as payment providers or delivery organisations, who will act on our behalf only;
  • with our service providers in order to provide and improve our Service;
  • with our affiliates;
  • if we think doing so is necessary to protect the rights, property, security, or safety of us, our Service, our users, or the public;
  • to enforce our Customers’ Terms of Use, Members’ Terms of Service, and any other agreements;
  • to investigate and defend ourselves or others against any third-party claims or allegations;
  • while negotiating or in relation to a business transaction, such as a merger, change of control, sale of assets, or bankruptcy; and
  • whenever you consent to the sharing.

We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data.

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.

We may disclose anonymised data (such as aggregated statistics) about the users of our Service in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

INTERNATIONAL TRANSFERS

Where you have requested tickets, goods or services for events based outside of the EEA, we are required to transfer your personal data out of the EEA to such Vendors in order to fulfil your request. Such transfer will be necessary to fulfil your request.  

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• 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 European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

SECURITY

We are committed to protecting the security of your personal data.  

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.

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.

RETENTION

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.

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.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the above rights, please contact us legal@pollen.co.

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.

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.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you are unsure about your rights or are concerned about how your personal data may be processed you should contact your national data protection regulator.  

You can unsubscribe from our promotional emails at any time via the unsubscribe link provided in the emails. Please note that you may continue to receive administrative messages from us even if you opt out of receiving promotional messages.

It is important that the personal data we hold about you is accurate and current. Please contact us at support@pollen.co if your personal data changes during your relationship with us.