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THE FOLLOWING DOCUMENT.
Last Updated: March 11, 2019
We participate in and comply with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data (defined in Section 2.1) transferred from European Economic Area ("EEA") member countries, Switzerland and the United Kingdom (UK) to the United States. You can find out more about our commitment to the EU-U.S. and Swiss-U.S. Privacy Shield Framework in our Privacy Shield Notice.
NOTE: To learn more about youin's Legal Terms, take a look here. 1-2
1. Who We Are.
1.1 youin Services.
Welcome to youin! We are an event, ticketing and registration platform dedicated to bringing the world together through live experiences. Through our platform, mobile apps and services, we enable people all over the world to create, discover, share and register for events.
1.2 Who's Who.
youin is mobile application fully owned and developed by the company DGPI Global Ltd with its principal place of business at 8/2 Vassallo Building Isouard Street Mosta Malta VAT MT24724621 ("youin," "us," "we" or "our"). If you are resident in the EEA or Switzerland, youin is the responsible party with respect to Personal Data (defined below) collected through the Services. youin's representative for European data protection law purposes is youin
If you have any questions or concerns at any time, please do not hesitate to contact us at the address above or by contacting us at email@example.com
2. Our Privacy Statement. 2.1 Application.
3. Personal Data That We Collect.
When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Organizer using our Services to run an event. This is an important distinction for EU data protection law purposes and is explained in more detail in Section 16 below.
3.1 Information Collected From All Users.
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and any other information that you choose to provide and/or that enables Users to be personally identified.
Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services ("Automatic Data"). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar
When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
3.2 Information Collected From Organizers.
If you are an Organizer we will collect additional Personal Data from you.
Information you provide to us: In some cases, we may collect your credit card information (e.g., your credit card number and expiration date, billing address, etc.), some of which may constitute Personal Data, to secure certain payments. In addition, if you use our payment processing services, we will collect financial information from you (e.g., your bank account information or an address to send checks) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
Information we obtain from other sources: We may also collect or receive Personal Data including your name, email address and other contact information from third party sources, such as third party websites and marketing partners, your bank, our payment processing partners and credit reporting agencies.
3.3 Information Collected From Consumers.
If you are a Consumer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Organizer (see Section 16 below for more information).
Information you provide via youin Properties or Applications: If you register for a paid event, you will provide financial information (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data. In addition, Organizers can set up event registration pages to collect virtually any information from Consumers in connection with registration for an Organizer's event listed on the Services. youin does not control an Organizer's registration process nor the Personal Data that they collect. When you register for, or otherwise provide information to youin in conjunction with an Organizer event or activity, whether that information is yours or a third party’s, in connection with a purchase, registration, or transfer, that Organizer will receive and may use the information you provide. Please see Section 5.5 below, titled “How We Disclose and Transfer Your Personal Data: Organizers” for more information about an Organizer’s receipt and use of your Personal Data.
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Organizers, other Consumers, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.
4. How We Use Your Personal Data.
4.1 Specific Reason.
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your questions or resolve your problem and will respond to the email address from which the contact came.
4.2 Access and Use.
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
4.3 Internal Business Purposes.
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
4.4 youin Marketing.
We may use your Personal Data for our marketing and advertising purposes, including (without limitation) by email, SMS marketing, display media, and targeting other devices (such as tablets, mobile devices and televisions). We do this in order to inform you about services or events we believe might be of interest to you, develop promotional or marketing materials and display youin or event-related content and advertising on or off the Services that we believe might be of interest to you. We may also do this on behalf of an Organizer, for example where your prior interactions with an Organizer suggest you may be interested in a particular type of event. See
"Opt Out from Electronic Communications" below on how to opt out of various youin marketing communications.
You may see advertisements for our Services (or our Organizer’s events) on third party websites, including on social media platforms. Where you see an advertisement on a third party website or social media platform, this may be because we engaged the third party or social media platform to show this advertisement to our Users, or to others who have similar attributes to our Users. In some cases, this involves sharing your email address or other contact details with the third party or social media platform so that they can identify you as one of our Users, or identify other individuals with similar attributes to you in order to show them advertisements for our Services (or for our Organizer’s events). If you no longer want your Personal Data to be used for these purposes please contact us at firstname.lastname@example.org For more information about how we market on, and interact with social media sites, please refer to section 5.6.
4.5 Organizer Emails.
We allow Organizers to use our email tools to contact Consumers for their current and past events, so you may receive emails from our system that originate with such Organizers and that we send on their behalf. If you registered for an event on the Services, your email address is available to that Organizer. However, Organizers may also import the email addresses they have from external sources and send communications through the Services to those email addresses, and we will deliver those communications to those email addresses on the Organizer's behalf. The Organizer and not youin is responsible for sending these emails. See "Opt Out from Electronic Communications" below on how to opt out of Organizer-initiated communications.
4.6 Use of Interest-Based Data
We sometimes make inferences about the type of events or activities you may be interested in. We may use these inferences to help target advertising or customize recommendations to you, including on behalf of Organizers. We may do this on an aggregated or generalized basis. For instance, we may determine that our users who attend many comedy events also often attend or show interest in endurance-related events or content. We may direct (or assist in directing) content or recommendations related to both comedy and endurance to those Users.
4.7 Other Purposes.
4.8 Aggregated Personal Data.
5. How We Disclose And Transfer Your Personal Data.
5.2 Business Transfers.
5.3 Parent Companies, Subsidiaries and Affiliates.
5.4 Agents, Consultants and Service Providers.
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of youin to perform wcertain business-related functions. These companies include our marketing agencies, online advertising providers, data enhancement and data services providers, database service providers, backup and disaster recovery service providers, email service providers, payment processing partners, customer support, tech support, hosting companies and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
When you purchase tickets to, register for or donate to an event, transfer an event ticket or registration to another person, enter a contest, or otherwise input your Personal Data (such as through a web form), or otherwise communicate with an Organizer, or participate in or express interest in an Organizer or Organizer event or activity, that Organizer will receive the information you provide, including your Personal Data, and where a ticket or registration is transferred, the Personal Data of the transferee as well. Other third parties that are involved in or on whose behalf an event or activity is promoted, may receive that Personal Data as well.
For example, as to fundraising pages, we may provide your Personal Data both to the Organizer charity of the fundraising page and the Organizer of the event to which the fundraising page is linked. In some instances, an Organizer may appoint a third party, which may or may not be affiliated with the Organizer, to create an event or fundraising page on its behalf (we call these third parties ("Third Party Organizers"). For example, and without limitation, a concert venue (the Organizer, in this case) may allow third party promoters or production companies (the Third Party Organizers) to create events that will be hosted at the Organizer's venue using its youin account. In that case, we may provide your Personal Data to the Third Party Organizers on behalf of the Organizers. The same is true for contests and sweepstakes: we may provide your Personal Data to both the Organizer promoting the contest or sweepstakes, and any legal sponsor of the contest or sweepstakes (such as a brand sponsor).
We are not responsible for the actions of these Organizers, or their Third Party Organizers (or other downstream recipients of your Personal Data), with respect to your Personal Data. It is important that you review the applicable policies of the Organizers, and if applicable and available, their appointed Third Party Organizers, of an event (and the related fundraising page, if applicable) before providing Personal Data or other information in connection with that event or related fundraising page.
Similarly, if you are a member of an Organizer's organization within youin, your Personal Data will be available to the Organizer and shared with those Third Party Organizers granted permission by the Organizer to view all members of the Organizer's organization.
b. “Liking” or “Following” youin on Social Media. In addition, when you “like” or “follow” us on Facebook, Instagram, Twitter or other social media sites (to the extent we provide that
capability), we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We likewise may collect your information if you sign up for one of our promotions or submit information to us through social media sites.
c. Facebook Plug-Ins and Links on Our Pages. youin’s own website may contain links to Facebook as well, such as through the Facebook “Like” or “Share” button or other social plug-ins. When you interact with these features and links, your browser will establish a direct link with the Facebook servers, and Facebook will receive information about your browser and activity, and may link it to your Facebook user account. For more information about how Facebook uses data, please see Facebook’s own policies.
d. Additional Facebook Marketing and Connectivity. In addition, if you are a member of Facebook (or another social media platform), and you provide Personal Data to an Organizer (such as in the ways described in Section 5.5), the Organizer may use that Personal Data to send you advertising and offers through Facebook (or another social media) platform, including when you are on Facebook or another social media platform. The Organizer may work with us and with third parties to enable this data integration and advertising. Facebook and other social media platforms may provide a way to opt out of this type of advertising. Please review their user settings and support pages to learn more about how they help you to manage privacy and marketing choices.
e. Third party services and integrations. youin may provide you with opportunities to contract directly with third parties, and/or to integrate with third party services or applications, through our platform. In such instances, we will disclose your Personal Data to other entities in order to fulfill a request by you, or to provide services you have requested.
5.7 Legal Requirements.
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
6. How We Store Your Personal Data.
network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.
7. How You Can Access, Update, Correct or Delete Your Personal Data.
You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.
If you are a registered User, you can exercise these rights by logging in and visiting the My Account page. Both registered and unregistered Users may also exercise these rights by contacting us directly by email or at the address specified below.
If a Consumer initiates a data deletion request, youin is authorized to delete or anonymize Personal Data of the requesting Consumer from the Services even if that means removing its availability to the Organizer through the Services. However, if you are a Consumer, you understand that even if youin deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Organizer's own databases if transmitted to the Organizer prior to youin receiving or taking action on any deletion or anonymization activity.
We will consider and respond to all requests in accordance with applicable law. 8. How Long We Retain Your Personal Data.
We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
9. Cookies, Pixels Tags, Local Shared Objects, Web Storage And Similar Technologies.
10. Your Choices.
You have several choices available when it comes to your Personal Data: 10.1 Limit the Personal Data You Provide.
You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to buy tickets as a Consumer, your name and email address will be required by the Organizer.
10.2 Opt Out from Electronic Communications. (a) youin Marketing Communications.
Where it is in accordance with your marketing preferences, youin may send you electronic communications marketing or advertising the Services themselves or events on the Services, to the extent you have registered for the Services or purchased a ticket and/or registration to an event listed on the Services. You can also "opt out" of receiving these electronic communications by clicking on the "Unsubscribe" link at the bottom of any such electronic communication. In addition, you may also manage your email preferences at any time by logging in (or signing up and then logging in), clicking on "Account" and then "Email Preferences."
(b) Organizer-initiated Communications.
Organizers may use our email tools to send electronic communications to those on their email subscription lists, including Consumers who have registered for their events on the Services in the past. Although these electronic communications are sent through our system, youin does not determine the content or the recipients of these electronic communications. Organizers are required to use our email tools only in accordance with all applicable laws. youin provides an "Unsubscribe" link on each of these emails, which allows recipients to "opt out" of electronic communications from the particular Organizer.
(c) Transactional or Responsive Communications.
Certain electronic communications from youin are responsive to your requests. For instance, if you are a Consumer, we must email you your ticket or registration on behalf of the Organizer when you purchase such ticket or registration. As a further example, if you email our customer support department, we will return your email. Notwithstanding any unsubscribe election that you have made, you will still receive these transactional or responsive emails. You can stop receiving these types of emails only by contacting us. By electing to stop receiving all electronic communications from us or through our system, you will no longer receive any updates on events you have created (including payout issues) or on events you are registered to attend (including emails with your tickets). We do not recommend that you do this unless you plan to no longer use the Services, are not currently registered for an event, are not currently organizing an event, and will have no need to receive further communications from us or through our system.
10.3 Do Not Track.
We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.
11.1 Personal Data Provided to Others.
11.2 Third Party Links.
12. Children - Children's Online Privacy Protection Act.
13. International Privacy Laws.
15. Dispute Resolution.
If you have a complaint about youin's privacy practices you should write to us at:
youin Attn: DGPI GLOBAL LTD 8/2 Vassallo Building Isouard Street Mosta Malta, or by email@example.com. We will take reasonable steps to work with you to attempt to resolve your complaint.
Residents of the EEA, Switzerland or the UK who believe that their information has not been processed in compliance with the Privacy Shield Principles may raise their complaints in a number of ways. For further information, please see our Privacy Shield Notice.
16. EEA, SWITZERLAND AND UK ONLY
The EU General Data Protection Regulation (GDPR)
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the "GDPR") went into effect.
The GDPR requires youin and Organizers using the Service to provide Users with more information about the processing of their Personal Data.
Here is what you need to know:
Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Section 4 above will typically be because:
• you provided your consent;
• it is necessary for our contractual relationship;
• the processing is necessary for us to comply with our legal or regulatory obligations; and/or • the processing is in our legitimate interest as an event organizing and ticketing platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).
Transfers of Personal Data
As youin is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe.
Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. For Personal Data we receive from the EEA, Switzerland and the UK, youin, Inc has certified its compliance to the EU-U.S. and Swiss-U.S. Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from those countries. We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability when processing Personal Data from the EEA, Switzerland or the UK in the United States. You can find out more about our commitment to the EU-U.S. and Swiss-U.S. Privacy Shield Framework in our Privacy Shield Notice.
Feel free to contact us as set forth in Section 15 for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
If you have an account with us, we will typically retain your Personal Data for a period of ninety (90) days after you have requested that your account is closed or if it's been inactive for seven (7) years.
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.
For the most part, you can exercise these rights by logging in and visiting the My Account page or changing the "cookie settings" in your browser (see our Cookie Statement for more information). If you can't find what you're looking for in the My Account page, please contact us using the contact information set out in Section 15 above. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.
If you have a complaint about how we handle your Personal Data, please get in touch with us as set forth in Section 15 to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
youin as a data controller and a data processor
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
youin may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
For example, if you create an account with us to organize your events, youin will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or youin Properties, which could relate to Organizers or Consumers. We use this to conduct research and analysis to help better understand and serve Users of the Services as
well as to improve our platform and provide you with more targeted recommendations about events we think may be of interest to you.
However, if you register for an event as a Consumer, we will process your Personal Data to help administer that event on behalf of the Organizer (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Organizer target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness of various sales channels, etc.). In these circumstances, youin merely provides the "tools" for Organizers; youin does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organizer as the data controller, not to youin.