Last
Updated: March 23, 2020
We
participate in and comply with The EU General Data Protection Regulation (GDPR)
regarding the collection, use, and retention of Personal Data from European
Economic Area ("EEA") member countries and of that of the government of Suriname.
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1. Who We
Are.
1.1 DigiTix
Services.
Welcome to DigiTix!
We are a ticketing and registration platform dedicated to bringing Suriname
together through live experiences. Through our platform, mobile apps and
services, we enable organisers and people all over the country to create,
discover, share and register for events.
DigiTix's
products, features and offerings are available (a) online through various DigiTix
properties including without limitation, DigiTix.sr,; (b) Sponsorship and
marketing or distribution services; and (c) through mobile applications,
webpages, application programming interfaces, and subdomains
("Applications"). (a), (b), and (c) are collectively referred to as
"DigiTix Properties" or our "Services".
1.2 Who's
Who.
When this
Privacy Policy uses the term "Organizer" we mean event creators using
the Services to create events for consumers using our Services (a) to consume
information about, or attend, events ("Consumers"), or (b) for any
other reason. Organizers, Consumers and third parties using our Services are
all referred to in these Terms collectively as "Users",
"you" or "your".
DigiTix is
a brand name of Esolutions, and is a Dutch Company with its principal place of
business at Kruitberghof 60, 1104BC, Amsterdam, The Netherlands. If you are
resident in the EEA or Switzerland, DigiTix is the responsible party with
respect to Personal Data (defined below) collected through the Services.
If you have
any questions or concerns at any time, please do not hesitate to contact us using
the contact form on this page.
2. Our
Privacy Statement.
2.1
Application.
This
Privacy Policy sets forth our policy with respect to information that can be
associated with or which relates to a person and/or could be used to identify a
person ("Personal Data") that is collected from Users on or through
the Services. We take the privacy of your Personal Data seriously. Because of
that, we have created this Privacy Policy. Please read this Privacy Policy as
it includes important information regarding your Personal Data and other
information.
"Non-Personal
Data" as used in this Privacy Policy is therefore any information that
does not relate to a person and/or cannot be used to identify a person. When
you interact with the Services, we may collect Non-Personal Data. The
limitations and requirements in this Privacy Policy on our collection, use,
disclosure, transfer and storage/retention of Personal Data do not apply to
Non-Personal Data.
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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 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 other
information 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 technologies. You can find out more information about
how we use Cookies and other similar tracking technologies in our Cookie
Statement.
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
Organizers.
As 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 from
third party sources, such as third party websites, your bank, our payment
processing partners and credit reporting agencies.
3.3
Consumers.
As 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 DigiTix 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. DigiTix does not
control an Organizer's registration process nor the Personal Data that they
collect. Personal Data collected on behalf of Organizers is provided to the
Organizer of the applicable event in accordance with "How We Disclose and
Transfer Your Personal Data: Organizers" below.
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.
We collect
and use the Personal Data we collect in a manner that is consistent with this
Privacy Policy. We may use the Personal Data as follows:
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
question 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 analyse 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 DigiTix
Marketing Communications.
Where it is
in accordance with your marketing preferences, we may use your Personal Data to
contact you in the future for our marketing and advertising purposes, including
without limitation, to inform you about services or events we believe might be
of interest to you, to develop promotional or marketing materials and provide
those materials to you, and to display content and advertising on or off the
Services that we believe might be of interest to you. See "Opt Out from
Electronic Communications" below on how to opt out of DigiTix Marketing
Communications.
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 DigiTix is responsible for sending these emails. See
"Opt Out from Electronic Communications" below on how to opt out of
Organizer initiated communications.
4.6 Other
Purposes.
If we
intend to use any Personal Data in any manner that is not consistent with this
Privacy Policy, you will be informed of such anticipated use prior to or at the
time the Personal Data is collected or we will obtain your consent subsequent
to such collection but prior to such use.
4.7
Aggregated Personal Data.
In an
ongoing effort to understand and serve our Users better, we often conduct
research on our customer demographics, interests and behaviour based on
Personal Data and other information that we have collected. This research is
typically conducted on an aggregate basis only that does not identify you. Once
Personal Data is in an aggregated form, for purposes of this Privacy Policy, it
becomes Non-Personal Data.
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5. How We
Disclose And Transfer Your Personal Data.
5.1 No
Sale.
We are not
in the business of selling your Personal Data. We consider this information to
be a vital part of our relationship with you. Therefore, we will not sell your
Personal Data to third parties, including third party advertisers. There are,
however, certain circumstances in which we may disclose, transfer or share your
Personal Data with certain third parties without further notice to you, as set
forth below.
5.2
Business Transfers.
As we
develop our business, we might sell or buy businesses or assets. In the event
of a corporate sale, merger, reorganization, dissolution or similar event,
Personal Data may be part of the transferred assets. You acknowledge and agree
that any successor to or acquirer of DigiTix (or its assets) will continue to
have the right to use your Personal Data and other information in accordance
with the terms of this Privacy Policy.
5.3 Parent
Companies, Subsidiaries and Affiliates.
We may also
share your Personal Data with our parent companies, subsidiaries and/or
affiliates for purposes consistent with this Privacy Policy. Our parent
companies, subsidiaries and affiliates will be bound to maintain that Personal
Data in accordance with this Privacy Policy.
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 DigiTix to perform certain business-related
functions. These companies include our marketing agencies, database service
providers, backup and disaster recovery service providers, email service
providers 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.
5.5
Organizers.
When you
purchase tickets to, register for or donate to an event through the event page,
or through a related fundraising page on the Services, we provide the Personal
Data entered on the applicable event or related fundraising page to the
Organizers of such event or related fundraising page. For 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 DigiTix account. In that case, we may provide your Personal Data to the
Third Party Organizers on behalf of the Organizers. We are not responsible for
the actions of these Organizers, or their Third Party Organizers, 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 DigiTix, 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.
5.6 Facebook
and Other Third Party Connections.
You can
connect your DigiTix account to your accounts on third party services like
Facebook, in which case we may collect, use, disclose, transfer and
store/retain information relating to your account with such third party
services in accordance with this Privacy Policy. For example, if you connect
with Facebook, we store your Facebook id, first name, last name, email,
location, friends list and profile picture and use them to connect with your
Facebook account to provide certain functionality on the Services, like
recommending events that your Facebook friends are interested in and sharing
the events you are interested in, or attending, with certain groups of people
like your Facebook friends.
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.
We may
store Personal Data itself or such information may be stored by third parties
to whom we have transferred it in accordance with this Privacy Policy. We take
what we believe to be reasonable steps to protect the Personal Data collected
via the Services from loss, misuse, unauthorized use, access, inadvertent
disclosure, alteration and destruction. However, no 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.
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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, DigiTix 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 you DigiTix 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 DigiTix 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.
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9. Cookies,
Pixels Tags, Local Shared Objects, Web Storage And Similar Technologies.
Please
refer to our Cookie Statement for more information about our use of cookies and
other similar tracking 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 an Consumer, your name and email address will be required by the
Organizer.
10.2 Opt
Out from Electronic Communications.
(a) DigiTix
Marketing Communications.
Where it is
in accordance with your marketing preferences, DigiTix 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, DigiTix 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. DigiTix provides
an "Unsubscribe" link on each of these emails, which allows
recipients to "opt out" of electronic communications from the
particular Organizer.
(c) Social
Notifications.
If you
connect your Facebook account or sign up for other social media integrations
whose product features include social notifications (i.e., updates on what your
friends are doing on the Services), you will receive these social
notifications. You can manage these social notifications by toggling your
social settings to private or disconnecting such integration.
(d)
Transactional or Responsive Communications.
Certain
electronic communications from DigiTix 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 pay-out
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.
(e)
Retention.
It may take
up to forty-eight (48) hours for us to process an unsubscribe request. Even
after you opt out of all electronic communications, we will retain your
Personal Data in accordance with this Privacy Policy, however, we will no
longer use it to contact you. However, Organizers who have received your
Personal Data in accordance with this Privacy Policy may still use that
Personal Data to contact you in accordance with their own privacy policies, but
they may not use our system to do so.
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.
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11.
Exclusions.
11.1
Personal Data Provided to Others.
This Privacy
Policy does not apply to any Personal Data that you provide to another User or
visitor through the Services or through any other means, including to
Organizers on event pages or information posted by you to any public areas of
the Services.
11.2 Third
Party Links.
This
Privacy Policy applies only to the Services. The Services may contain links to
other websites not operated or controlled by us (the "Third Party
Sites"). The policies and procedures we described here do not apply to the
Third Party Sites. The links from the Services do not imply that we endorse or
have reviewed the Third Party Sites. We suggest contacting those sites directly
for information on their privacy policies.
12.
Children - Children's Online Privacy Protection Act
We do not
knowingly collect Personal Data from children under the age of thirteen (13).
If you are under the age of thirteen (13), please do not submit any Personal
Data through the Services. We encourage parents and legal guardians to monitor
their children's Internet usage and to help enforce our Privacy Policy by
instructing their children never to provide Personal Data through the Services
without their permission. If you have reason to believe that a child under the
age of 13 has provided Personal Data to us through the Services, please contact
us and we will endeavor to delete that information from our databases.
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13.
International Privacy Laws.
If you are
visiting the Services from outside the United States, please be aware that you
are sending information (including Personal Data) to the United States where
our servers are located. That information may then be transferred within the
United States or back out of the United States to other countries outside of
your country of residence, depending on the type of information and how it is
stored by us. These countries (including the United States) may not necessarily
have data protection laws as comprehensive or protective as those in your
country of residence; however, our collection, storage and use of your Personal
Data will at all times continue to be governed by this Privacy Policy.
EU - US
Privacy Shield
For
Personal Data we receive from the EEA, DigiTix, Inc has certified its
compliance to the EU-US Privacy Shield as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal data from the
European Union 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 in the
United States. You can find out more about our commitment to the EU-U.S.
Privacy Shield Framework in our EU-US Privacy Shield Notice.
14. Changes
To This Privacy Policy.
The
Services and our business may change from time to time. As a result, at times
it may be necessary for us to make changes to this Privacy Policy. We reserve
the right, in our sole discretion, to update or modify this Privacy Policy at
any time (collectively, "Modifications"). Modifications to this
Privacy Policy will be posted to the Site with a change to the
"Updated" date at the top of this Privacy Policy. In certain
circumstances DigiTix may, but need not, provide you with additional notice of
such Modifications, such as via email or with in-Service notifications.
Modifications will be effective thirty (30) days following the
"Updated" date or such other date as communicated in any other notice
to you.
Please
review this policy periodically, and especially before you provide any Personal
Data. This Privacy Policy was updated on the date indicated above. Your
continued use of the Services following the effectiveness of any Modifications
to this Privacy Policy constitutes acceptance of those Modifications. If any
Modification to this Privacy Policy is not acceptable to you, you should cease
accessing, browsing and otherwise using the Services.
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15. Dispute
Resolution.
If you have
a complaint about DigiTix's privacy practices you should write to us at:
DigiTix,
Inc., Attn: Privacy Officer, 155 5th Street, Floor 7, San Francisco, CA 94103,
USA, or by email. We will take reasonable steps to work with you to attempt to
resolve your complaint.
Residents
of the EEA 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") becomes effective. The GDPR requires DigiTix 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 organising 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 DigiTix
is a international 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 example, DigiTix, Inc is Privacy Shield certified
which means that it self-certifies to protect Personal Data from the EEA,
Switzerland and the UK in accordance with established data privacy principles.
You can learn more here. 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
90 days after you have requested that your account is closed or if it's been
inactive for 7 years.
Your
rights.
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 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.
DigiTix 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.
DigiTix 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, DigiTix 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 DigiTix 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, DigiTix merely provides the "tools" for Organizers; DigiTix
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 DigiTix.