True Tickets

Privacy Policy

Effective Date: November 29, 2023

True Tickets provides a digital ticketing delivery service that live event venues can use to provide their customers with tickets they have purchased or received, as well as to let individuals share tickets with one another. This Privacy Policy (“Policy”) describes how True Tickets (“True Tickets,” “we,” “our,” “us”) processes personal information when you use the True Tickets webapp (“App”) or when you visit the True Tickets website (collectively, the “Services”). By using the Services, you are agreeing to the terms of this Policy.

This Policy only applies to information we collect through your use of the Services and not information we may collect in other contexts.

Information We Collect and Maintain About You

When you use the True Tickets App, we collect your email or username, as well as your password, for the ticketing venue so that we can verify your credentials. If you do not have an account with the ticketing venue, we collect your name, email address, and password through the App. We may also collect your phone number and mailing address through the App.

We also collect personal information from users when you provide it directly to True Tickets, for example, when you submit a form through our website, email us through a link on the website, or apply for a job with us. We may also collect information about you from third parties pursuant to your permission or consent.

We further automatically collect certain information about you and your smartphone or other device when you use, access, or interact with our website. We collect this information using the following mechanisms:

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our website on a particular time and day and collect information such as your device ID.

Cookies. We also use cookies on the website. Cookies are small files that are stored on your mobile device through the website. A cookie allows the website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the website during your current session and over time (including the pages you view and the files you download), your mobile device’s operating system, your device ID, and your general geographic location.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our website, viewed a particular advertisement, or opened a specific email.

How We Use Your Information

We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we use your information include to:

Provide you with the Services;
To verify your account or create a new account with a ticketing venue;
Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
Fulfill the terms of any agreement you have with us;
Allow users of the Services to share tickets with one another;
Respond to your questions or requests concerning the Services;
Deliver confirmations, account information, notifications, and similar operational communications;
Improve your user experience and the quality of our products and services;
Enforce our Terms of Service or alert you to changes in our policies or agreements that may affect your use of the Services;
Comply with legal and/or regulatory requirements;
Aggregate and deidentify information;
Analyze how visitors use the Services and various features, including to count and recognize users of the Services;
Create new products and services; and
Manage our business.

We may link information gathered through the Services with information that we collect in other contexts. In that event, we will handle the combined information in a manner consistent with this Policy.

With Whom and Why We Share Your Information

We may share any of the information described in “Information We Collect and Maintain About You,” above, with third parties for a variety of purposes, as described below.

Ticketing Venues. True Tickets provides a digital ticketing delivery service that its venue customers can use to facilitate ticket sales with end users. We share personal information that we process on behalf of our ticketing venue customers with them.

Third-party service providers. True Tickets uses third-party service providers that perform services on our behalf, including web-hosting companies. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.

We may also share your information with third parties when necessary to fulfill your requests for the Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs from your device. For example, we partner with Google Analytics for some of these services. You can learn about how Google Analytics uses data when you access our website here, and can opt out of being tracked by Google Analytics across all websites here.

Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

To comply with applicable law or a court order, subpoena, or other legal process;
To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
To establish, protect, or exercise our legal rights or defend against legal claims; or
To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated or deidentified information. We may also share aggregated or deidentified information about users of the Services, such as by publishing a report on trends in the usage of the Services. Such aggregated or deidentified information will not identify you personally.

Your Choices

If you have any questions concerning True Tickets’ privacy practices or wish to access, correct, or delete personal information that True Tickets may have collected from you, please contact us by mail or email at:

Privacy Officer
True Tickets, Inc
ATT: Privacy Policy
6 Liberty Square, Suite 2021
Boston, MA 02109

info@true-tickets.com

If you wish to opt-out of marketing emails you receive from us, you may do so by following the instructions in those emails or by contacting us at the above email address.

If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:

The right to access your personal information (including a data portability request);
The right to correct or amend any personal information we have on file about you;
The right to delete your personal information;
The right to limit the use of your “sensitive” personal information;
The right to opt-out of the sale or “sharing” of your personal information;
The right to opt-out of the use of your personal information for targeted advertising purposes;
The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
The right to restrict or opt-out of the use of your personal information for certain automated decision-making (including profiling in furtherance of decisions that produce legal or similarly significant effects);
The right to revoke your consent (to the extent applicable);
The right to confirm whether personal information about you is being processed; and
The right to obtain a list of specific third parties (or categories of third parties) to which we have disclosed your personal information or any personal information.

To exercise any of the rights listed above, please contact us via email at info@true-tickets.com. Please note that we do not sell or share your personal information for purposes of online behavioral advertising, nor do we collect sensitive personal information or use your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects.

We will respond to your request as soon as reasonably possible but no longer than 30 days. We will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to info@true-tickets.com with the subject line “Appeal of Decision Related to Privacy Rights Request.” Depending on your jurisdiction, you may also have the right to lodge a complaint to your local data protection authority.

Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you.

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

If you are a resident of California, please review the California Privacy Addendum, below, for additional rights that may apply to you.

External Links

The Services may contain links to third-party websites or services. If you use these links, you will leave the Services. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security

The personal information we collect about you is stored in limited access servers. We will maintain reasonable safeguards to protect the security of these servers and your personal information. However, no security measures are 100% effective and we cannot guarantee the security of your personal information.

Data Retention

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International Users

All personal information we collect from users in the UK or EU is stored in the EU. For all other users, end user personal information we collect through or in connection with the Services may be transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. While your personal information is in these other countries, it may be accessed by those countries’ courts, law enforcement, and national security authorities. By using the Services or by providing any information to us, you expressly consent to such transfer and processing.

To obtain more information about our data transfer policies and practices, please contact our Privacy Officer using the methods described in “How to Contact Us,” below.

Children

The Services are not directed to children under 13 (or other age as required by local law). We do not knowingly collect personal information from children under the age of 13.

Changes to this Policy

We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, so you should review this page periodically. We will also notify you of any significant or material changes that are made to this Policy.

How to Contact Us

Should you have any questions or concerns about this Policy, you can contact us at:

Privacy Officer

True Tickets, Inc
ATT: Privacy Policy
6 Liberty Square, Suite 2021
Boston, MA 02109

info@true-tickets.com

CALIFORNIA PRIVACY ADDENDUM

Date Last Updated: November 29, 2023

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to update or correct your information; the right to opt-out of the sale or sharing of your personal information; the right to limit our use of your sensitive personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also consult our Privacy Policy above for additional information and rights that may be available to you.

Collection of Personal Information

If you use the Services, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may have collected the following categories of personal information about you over the past 12 months:

Identifiers, such as your name, email address, and IP address
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name
Characteristics of protected classifications under California or federal law, such as your age
Commercial information, such as your transaction history
Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses
Geolocation data
Inferences drawn from any of the information identified above

We collect the personal information listed above from the sources listed above in our Privacy Policy, in the section titled “Information We Collect and Maintain About You.”

Disclosure of Personal Information

In the last 12 months, with your permission, we may have disclosed the following categories of personal information subject to the CCPA:

Identifiers, such as your name, email address, and IP address
Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name
Characteristics of protected classifications under California or federal law, such as your age
Commercial information, such as your transaction history
Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses
Geolocation data
Inferences drawn from any of the information identified above

We may have disclosed any of the information listed above with the entities described in our Privacy Policy for the purposes described in our Privacy Policy. Please review the section titled “With Whom and Why We Share Your Information” for additional information.

Your Rights

If we maintain personal information about you that is subject to the CCPA, you may exercise certain rights in connection with this data if you are a California resident.

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you

The categories of sources for the personal information we collected about you
The categories of personal information that we have disclosed for a business or commercial purpose
Our business or commercial purposes for collecting, selling, or sharing personal information
The categories of third parties with whom we share or disclose that personal information
The specific pieces of personal information we collected about you (i.e., a data portability request)

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/vendors to delete) your personal information from our records, unless an exception applies.

Right to Correct

California residents have the right to correct or amend the personal information we have on file (“Right to Correct”). You may correct or amend the personal information we have on file by contacting us using the information below.

Right to Opt Out of Sale or Sharing

The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their personal information (“Right to Opt Out”).

We do not sell or share your personal information. Accordingly, we do not have actual knowledge that we sell or share the personal information of California residents under the age of 16.

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides California residents with the right to limit the use of their “sensitive personal information” to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations.

We do not collect your sensitive personal information and therefore do not use sensitive personal information for any purposes outside of those permitted by § 7027(m).

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights

If you are a California resident and wish to exercise the above rights, you may submit a request to us by email at info@true-tickets.com or by mail at:

True Tickets, Inc
ATT: Privacy Policy
6 Liberty Square, Suite 2021
Boston, MA 02109

You may also exercise your rights by calling 855-878-3849.

When you submit a request, we may ask you for information in order to verify your identity in order to comply with your request.

Authorized Agent

Shine the Light Law

In addition to the CCPA, California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information for these purposes.

Contact for More Information

If you wish to contact us regarding this California Privacy Addendum, you may do so through the following methods:

By email at info@true-tickets.com
By mail at:

True Tickets, Inc
ATT: Privacy Policy
6 Liberty Square, Suite 2021
Boston, MA 02109
By phone at: 855-878-3849