LAST UPDATED 4 NOVEMBER 2020
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 website is not intended for children and we do not knowingly collect data relating to children.
Pollen is the controller and responsible for your personal data.
Full name of legal entity: StreetTeam Software Limited
Email address: firstname.lastname@example.org
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.
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
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 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:
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:
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.
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 email@example.com.
We may also share your information with third parties in the following situations, to the extent permitted by law:
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.
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.
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.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the above rights, please contact us firstname.lastname@example.org.
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 email@example.com if your personal data changes during your relationship with us.