Last Updated: June 8, 2022
- Personal Information We Collect
We collect Personal Information about you from different sources listed below. In this Policy, “Personal Information” means any information related to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).
Information Provided by You
- Account information. When you sign up to become a lead, register for our platform, apply to become a member, purchase an experience, have an experience transferred to you by a friend, or otherwise use the Services, you provide us with Personal Information, such as your name, age, email address, date of birth, telephone number, country, zipcode and password. You may also choose to provide us with Personal Information such as photo and experience preferences.
- Contact information and other information you choose to provide to us. When you contact us via the contact form on our website, via the chat function on our website, via email, or by other means, you provide us with Personal Information, such as your name, email address, telephone number, the contents of your communications, including the content of customer service calls, and nature of your correspondence with us.
- Support Information. When you request technical support services, we will process your Personal Information such as your name and the contact details you use to contact us, as well as information on the reasons for your support request, and any additional information you may provide in that context.
- Competitions, promotions and surveys. When you participate in competitions, promotions and surveys, you may provide us with specific Personal Information such as contact information, social media handles and the content of any such competitions, promotions, and surveys. If you win a competition, you may provide us with specific Personal Information, including your contact information and social security number, required for us to report your winnings to the IRS.
- Financial Information. If you purchase one of our online experiences or other products, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
- Vaccination and Testing Information. If you want to participate in one of our events, we will ask you to provide proof of vaccination against Covid-19 (i.e. original/copy/picture of vaccination card) or proof of a negative Covid-19 diagnostic test taken within 72-hours before arrival into each venue. If you want to enable our COVID-19 Money Back Guarantee, we may ask you to provide proof of a positive Covid-19 diagnostic test taken within 14 days of the experience start date.
- Information you post. We collect information you post in a public space on our website or on a third-party social media site.
- Accessibility and Dietary Information. We may collect details of your health requirements if you have accessibility requirements or dietary requirements when attending experiences.
Information Collected via Automated Means
- Identifiers and usage. When you use the Services we and third parties may automatically collect your IP address, advertising identifiers and potentially non-personal information about your device including model, version and operating system.
Information Collected from Other Sources
- Information from third parties. We obtain Personal Information about you from third parties, such our payment processor Stripe. This information includes transaction information, such as details of payments made, VAT due, and the timings of such payments. We may also receive information about you from social media sites if you use a social media feature within our websites or apps or post to a social media platform and from guest lists from third parties, including names and emails. We may collect your Covid-19 status and relevant Personal Information to administer admittance to events.
We also collect, use and share aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of our Services to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy.
- How We Use Personal Information
We will use your Personal Information for one or more of the following purposes:
- Providing you with the Services. We use your Personal Information to operate, maintain and provide you with the Services. In particular we will use your Personal Information to perform our contractual obligation towards you to allow you to create an account, sign-up to receive more information about an event or from a business partner, browse our website, purchase and participate in experiences, maintain a record of such purchase(s), and to contact you in case of any issue with your account. The Personal Information we process when doing so includes your registration, contact, and transaction information.
- Providing you with support and to respond to your requests and complaints. If you reach out to us for support, we will perform our contractual obligation towards you by using your Personal Information to respond and resolve your queries and facilitate support. The Personal Information we process when doing so includes your correspondence with us, your name, contact details, and, to the extent applicable to your query or complaint, transaction and usage information.
- Performing any payments requested by you and executing payment transactions.
- Improve or monitor usage of our Services. It is in our legitimate interests to improve our Services for our users, which includes conducting troubleshooting, testing and research and to keep the Services secure. When doing so we may use Personal Information that we automatically collect about you, such as identifiers and information on use.
- To monitor and analyse trends and use of our Services. It is in our legitimate interests to analyse the use of our Services. When doing so, we will process Personal Information that we automatically collect about you or that is generated about you when you use the Services.
- To enforce our Terms and Conditions, to comply with legal obligations and to defend Pollen against legal claims or disputes. It is in our legitimate interests to enforce our terms and policies, to ensure the integrity of our Services and to defend ourselves against legal claims or disputes. Where we do so, we will use the Personal Information relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on Pollen, for example to keep records of transactions.
- Marketing. Unless you have opted out of receiving marketing communications, it is in our legitimate interests to use your Personal Information to communicate with you regarding promotions, events, and other news, products or services we think will be of interest to you. You can opt out of such communications when you register an account with us, by following the unsubscribe mechanism, or by otherwise emailing us at firstname.lastname@example.org. We will also share your information with business partners, including third parties that provide an experience. This can include promoters, musicians, artists, sponsors, venues, hotels, and their respective teams. Our business partners use this information as described in their privacy policies, which may include sending you marketing communications. To opt out of such communications, please contact the third party business partners.
- Push Notifications. We may use push notifications and your location information in our apps to send you information and alerts, including about experiences that you are attending.
- Our Use of European Personal Information
If you are in the European Economic Area (EEA), the UK or Switzerland we only process your Personal Information when we have a valid legal basis.
- Consent. We may use your Personal Information when you have given your consent to do so. For example, to send you marketing communications.
- Contractual necessity. We may use your Personal Information to perform our end of our contracts with you. For example, to provide you with the Services.
- Legal obligation. We may use your Personal Information when we are legally required to. For example, to comply with tax and accounting obligations, or to comply with a court order.
- Legitimate interest. We may use your Personal Information when we, or a third party, have a legitimate interest in doing so. For example, we have a legitimate interest in understanding usage and improving the Services. We only rely on our or a third party’s legitimate interests to process Personal Information when these interests are not overridden by your rights and interests.
Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies: Some cookies are strictly necessary to make our website available to you; for example, to perform your login functionality and for user authentication and security. We cannot provide you with the website without this type of cookies.
- Functional cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your account preferences.
You can block cookies by setting your internet browser to block some or all or cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
- Who we Share Your Information With
We disclose Personal Information about you with the following recipients and in the following circumstances:
- Vendors and service providers. We rely on vendors and service providers for the provision of our Services, such as:
- Partners such as festival partners, sponsors, and ticketing partners;
- Experience providers such as vendors, venues, hotels, and wristband providers;
- Promoters, artists, and performers;
- Providers of marketing communication and CRM tools, for instance Iterable, Mailchimp, and MailGun;
- Customer experience management providers who help us manage and evaluate our customer experience contracts, such as Zendesk;
- Cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you, such as Amazon Web Services and Datadog;
- Analytics providers who help us to understand our user base and how our Services are used, such as Google Analytics, Segment, and Mixpanel;
- Providers of business communication tools, such as Slack and Monday.com;
- Payment processors. We disclose your information to payment processors, such as Stripe in order to receive payment for any purchases that you make in connection with the Services.
- Pollen group. We share Personal Information about you with our affiliates and subsidiaries.
- Legal. Information about our users, including Personal Information, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Pollen, our users, a third party, or the public.
- Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Personal Information as part of that transaction.
- Your Rights and Choices
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional materials. If you do not wish to have your email address or other contact information used by Pollen for marketing purposes to promote our own or our affiliates’ or subsidiaries’ products or services, you can opt out by contacting us as set out in the “Contact Us” section below. If we have sent you a newsletter or promotional email, you may opt-out of receiving them by following the instructions included in each newsletter or communication.
- Accessing, deleting and correcting your information. You may contact us as set out in the “Contact Us” section below to request access to, correct or delete any Personal Information that we have about you. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Your European Privacy Rights
If you are in the EEA, the UK or Switzerland you also have the following additional rights in relation to your Personal Information that we hold.
- Access. You have the right to access the Personal Information we hold about you, and to receive an explanation of how we use it and who we share it with.
- Correction. You have the right to correct any Personal Information we hold about you that is inaccurate or incomplete.
- Erasure. You have the right to request for your Personal Information to be erased or deleted.
- Object to processing. You have the right to object to our processing of your Personal Information where we are relying on a legitimate interest or if we are processing your Personal Information for direct marketing purposes.
- Restrict processing. You have a right in certain circumstances to stop us processing your Personal Information other than for storage purposes.
- Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Personal Information that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Personal Information to a third party.
Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. For more information on your rights, please email email@example.com.
- Cross-Border Data Transfers
If you provide us with your Personal Information when using the Services from EEA, Switzerland or the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing.
We may transfer your Personal Information outside of the EEA. When we do so, we shall ensure that relevant safeguards are in place to afford adequate protection for your Personal Information. Further details regarding the relevant safeguards can be obtained from us on request.
- Children’s Privacy
Our website is not directed to children, and we do not knowingly collect Personal Information from children under the age of 18. If you learn that a child has provided us with Personal Information in violation of this Policy, please contact us as indicated below.
- Third parties
The Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, and governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services and we encourage you to learn about third parties’ privacy and security policies before providing them with your Personal Information.
- Data Retention
Pollen stores all Personal Information for as long as necessary to fulfil the purposes set out in this Policy, or for as long as we are required to do so by law or in order to comply with a regulatory obligation. When deleting Personal Information, we will take measures to render such Personal Information irrecoverable or irreproducible, and the electronic files which contain Personal Information will be permanently deleted.
- Data Security
We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. However, the transfer of Personal Information through the internet will carry its own inherent risks and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.
- Changes to this Policy
We may update this Policy from time to time to reflect changes in our privacy practices. It is our policy to post any changes we make to this Policy online. The date the Policy was last revised is identified at the top of the page. Please monitor our website and this Policy periodically to check for any changes. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account and/or through a notice on the website home page.
If you wish to lodge a complaint about how we process your Personal Information, please contact us at firstname.lastname@example.org. We will endeavour to respond to your complaint as soon as possible. You may also lodge a claim with the Information Commissioner’s Office in the UK or the data protection supervisory authority in the EU country in which you live or work, where you believe we have infringed data protection laws.
- Our Contact Information
Pollen is the entity responsible for the processing of your Personal Information, and for the purpose of the European Union’s General Data Protection Regulation (GDPR), is the data controller in respect of the processing of your Personal Information. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please contact us by email at email@example.com.
If you are in the EEA or Switzerland you may contact our data protection representative at:
Osano International Compliance Services Limited
25/28 North Wall Quay
Dublin 1, D01 H104