Privacy Statement

Last update: May 2019

Who are we and what do we do?

We are TicketSwap B.V., acting under the name TicketSwap. You can find our contact information at the bottom of this Privacy Policy. TicketSwap is a safe, convenient and fair place to buy and sell e-tickets for concerts, festivals, sports events, theatre and days out, with a focus on fraud prevention by strict checks and collaborations with organizations and partners (the Services). You can find more information about us and our Services on our Website: www.ticketswap.nl (and all its subdomains for other countries) (the Website) or on the mobile application offered under the name TicketSwap (the App).

In this Privacy Policy we explain which personal data we collect through our Services, Website and App. We also explain for which purposes we use personal data, how we secure them and how long we store them. At the bottom of this Privacy Policy we explain what rights you have with regard to your personal data and how you can exercise these rights.

Privacy and relevant legislation

We care about your privacy. We comply with the new General Data Protection Regulation (GDPR), which replaced the various privacy laws in European Member States as of 25 May 2018 and with the Dutch Telecommunications Act (Telecommunicatiewet, DTA). This legislation will be referred to hereinafter as the Relevant Legislation.

Personal Data

In this Privacy Policy the notion of “personal data” is understood as all the information by which you can be, directly or indirectly, identified. This definition is in accordance with the Relevant Legislation.

Which personal data do we collect and for what purposes do we use them?

We can collect various sorts of personal data of you when you use our Website, App and/or Services:

(Personal) Data	Purpose(s)
General Information Name, date of birth, gender, city and country of residence, telephone number, email address and avatar	We use your general information to contact you in the right manner; your email address to send you information and updates about your transaction(s); Based on your (optional) consent we may also send you information about topics that might be interesting for you through a newsletter; your avatar and city and country of residence to personalize your account; your telephone number to check whether it is real and it belongs to you. When you sell tickets, the verification of your phone number (and not the number itself) will be shown on our Websites to make the selling and buying of second hand tickets safer for (potential) buyers. When your ticket is sold we send a text message to your telephone number.
Payment Information Bank account, tokenized payment details and bank account holder name	We use your payment information to enable us - and the processors we work with – to process and record your payments.
Social Media Information Facebook app specific ID and Twitter ID	We use your Facebook ID, avatar, name, Facebook email address, friends and your residence to (enable you to) complete your account (optional). These "Facebook data" will be shown on our Websites and mobile apps when you sell tickets to make the selling and buying of second hand tickets safer for (potential) buyers. We further use Facebook IDs for marketing purposes, as described further in this Privacy Policy. Your Twitter ID, username, name, location, followers count, friends count, number of status updates, security status, verification status and account creation date to complete your account. There “Twitter data” will be shown on our Websites and mobile apps when you sell tickets to make the selling and buying of second hand tickets safer for (potential) buyers.
Google Login	Your Google ID, Google Mail. First Name, Last Name, Location, These "Google data" will be shown on our Websites and mobile apps when you sell tickets to make the selling and buying of second hand tickets safer for (potential) buyers. We further use Google Mail and Google ID for marketing purposes, as described further in this Privacy Policy.
Snapchat	Your Snapchat Public profile will be used by TicketSwap Apps based on the user confirmation. We may use Snapchat public profile for some marketing purposes as described further in this privacy policy.
Instagram	Your Instagram Public profile will be used by TicketSwap Apps based on the user confirmation. We may use Instagram public profile for some marketing purposes as described further in this privacy policy.
Electronic Identifiers IP address, cookies and pixels	We use Your IP address, cookies and pixels in order to communicate with you in a language you speak and to show you content that relates to the country you reside in.
Fraud Prevention Personal and technical information	We use We use personal data to prevent (users that have committed) fraud.

Why can we process your personal data?

There are several grounds from the Relevant Legislation on the basis of which we are allowed or required to process your personal data:

Consent: For sending newsletters and direct marketing through email we request your permission. This permission can also easily be withdrawn through the unsubscribe link in each newsletter.
Performance of the agreement: We process your general information, payment information, social information and electronic identifiers to provide our Services to you as a user.
Legal obligation: We are required to store certain general information and payment data in our records for Tax Authorities, such as invoice data and your country of residence.
Legitimate interest: For processing general information, payment information, social information and electronic identifiers, in order to log user activities to identify and prevent unlawful use of the account and Services.

Are under the age of sixteen?

If you are younger than sixteen years, you are not allowed to register your profile on our Websites or Apps. This is because the law (the General Data Protection Regulation) gives us strict rules on the personal data of minors.

How long do we keep the personal data?

It is our policy to only store and process personal data that is essential in providing you with the best service possible. We do not store or process personal data we don’t use.

We keep the personal data as long as we need them for the purposes stated above:

Personal data in our accounting records for Tax Authorities we store 10 years after you have bought or sold on our Platform;
Personal data we process to prevent (users that have committed) fraud we store 5 years after your last login.

All other personal data we use within the context of your account we store for 2 years after your last login. If your account is inactive we will send you a notification after 2 years and remove your account and personal data if your account remains inactive. We will remove your personal data if you delete your account as well.

Do we share your personal data with others?

TicketSwap does not sell, trade or rent personal data to third parties. We make use of “Data Processors” however to assist us in our Services. Within this context these Data Processors receive personal data from us which they process by our order. By means of “Data Processing Agreements” we contractually obligate all the Data Processors we work with, not to process the personal data for any other purpose than as instructed by us. These Data Processors are required to follow our instructions strictly. They will, therefore, not use the personal data for their own purposes. We will verify that all our Data Processors comply with the Relevant Legislation.

We may transfer personal data outside the EU, if one of our Data Processors is established outside the EU. The personal data will only be transmitted to countries and/or parties offering an adequate level of protection which meets the European standards. We will check inter alia whether an organization outside the EU is listed in the Privacy Shield List and whether the level of protection of the third country has been approved by the European Commission. To learn more about the Privacy Shield Program, see here.

Transfer of data outside the EU will always be in accordance with the Relevant Legislation (such as Article 76(1) of the Dutch Data Protection Act – replaced as per 25 May 2018 by Chapter 5 of the GDPR).

The Data Processors we use for the processing of the personal data are listed in Annex 1.

We may share generic aggregated data with our business partners and trusted affiliates. In such case the data will be fully anonymized.

How do we protect personal data?

We protect all personal data we process from unauthorized and unlawful access, alteration, disclosure, use and destruction. For instance, we take among other things the following technical and organizational measures to protect the personal data:

Security of our network connections through Secure Socket Layer (SSL);
The (access to) data is secured with passwords and two factor authentication;
All new employees are trained about data privacy during onboarding;
Periodic training about data privacy to all employees;
Restricted access to databases containing personnel information to senior employees;
Pre-employment background screening of all employees.

Third-party websites

You can find (hyper)links on our Website which link to the websites of partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not have control of the content or links which appear on these websites and we are not responsible for the practices of websites linked to or from our Website. Furthermore, these websites, including their content and links, may constantly change. These websites may have their own privacy policies, user terms and customer policy. Browsing and interaction on any other website, including websites which are linked to or from our Website, are subject to the terms and conditions and policy of such website.

Cookies

We use cookies on the Website to enhance your experience when you use our Services. A cookie is a simple small text file that can be stored on your computer, when you visit the Website. This text file identifies your browser and/or computer. When you revisit our Website, the cookie ensures, for instance, that our Website recognizes your browser or computer.

We use the following types of cookies:

Technical cookies: Technical cookies are essential to the operation of our Website. They allow you to navigate through our Website and to use the functions incorporated in it.

Analytical or statistical cookies: Analytical cookies are used to check the quality and effectiveness of the Website. For instance, we can see how many users visit the Website and which pages are visited. We use this information to improve our Website and Services.

Tracking cookies: Tracking-cookies monitor the click and surf behaviour of our visitors. By means of these cookies we can see whether and when you look at your profile and whether you click through to our Website. We may also use these cookies to show you ads based on your interests. For more information about cookie tracking used for advertisements customized to your interests and how you can opt-out to these cookies you can use Your Online Choices or Cookiebot.

If you do not want cookies to be sent to your computer, you can change this in the cookie settings of your browser. Please note that some of the functions or services of our Website may not operate, or not so well, without cookies. If you want to opt-out from tracking cookies, click here:

Amendments to this Privacy Policy

We aim at constantly improving our Website and Services. That is why from time to time we can update this Privacy Policy. If we change our Privacy Policy significantly, then we will state so on our Website and App together with the reviewed Privacy Policy. We may also notify before using our services that our Privacy Policy has been updated. You need to agree to the updated Privacy Policy before you can continue to use our Website and App.

Your rights and our contact data

As laid down in the Relevant Legislation, you have the right to:

Access a copy of the personal data we process of yours. You can find a copy of the personal information we process of you here;
Ask us to rectify, review or remove your personal data from our systems;
Object to our processing of your personal data;
File a complaint with your National Data Protection Authority, if you believe that we process your personal data unlawfully. See here a list of all National Data Protection Authorities in the European Union.

Please note that you can also edit or delete your personal data by logging in to your personal account.

If you want to exercise your aforementioned rights or when you have any questions, comments or concerns regarding the manner in which we handle your personal data, please contact our Data Protection Officer through the contact data below. We will do our best to respond to any of the above requests within 30 days.

TICKETSWAP B.V.,

acting under the name TicketSwap

Rokin 75
1012KL Amsterdam
The Netherlands

No. Chamber of Trade and Industry: 59084952

VAT number: NL8533.10488.B01

Telephone: +31 20 308 06 76

E-mail: info@ticketswap.com

The Data Processors we use for the processing of personal data in order to deliver our Services are listed hereunder:

Processor	Purpose	Location	Explanation
Branch	Marketing / Analytics	California, US	Branch provides solutions that unify user measurement across different devices, platforms and channels. It fixes that by providing a holistic view of various user touch points and ensuring that links take the user to the right place on the website or native app. For more information refer to the Branch Privacy Policy.
Facebook	Marketing/Analytics	California, US	For Facebook we use the services of Facebook Custom Audience (see Facebook Business for more information). This means that the Facebook Data you shared with us, will be sent (back) to Facebook in a hashed format. Facebook is contractually obliged not to use said data for any other purpose than to render its audience targeting services. See here for the relevant terms. Included in the Privacy Shield list.
Firebase	Marketing/Analytics	California, US	Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. (“Google”). In order to understand Google's use of personal data, consult Google's partner policy. Firebase Analytics may share personal data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. This application uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal data collected: cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and usage data. See here for the details. Moreover; We’re also using Firebase for push notifications. We send notifications to drive user re-engagement and retention to our mobile apps. Included in the Privacy Shield list.
Google Adwords	Marketing/Analytics	California, US	Google AdWords is an online advertising service developed by Google where advertisers pay to display brief advertising copy, product listings, and video content within the Google ad network to web users (Google Display Network, Google Search, YouTube etc.). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts (such as: re-marketing/re-targeting purposes). You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests. See here for the details and relevant terms.
Google Analytics	Marketing/Analytics	California, US	Google Analytics is a web analysis service provided by Google. Google utilizes the personal data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the personal data collected to contextualize and personalize the ads of its own advertising network. Personal data collected are cookies and usage data. See here for the details. Included in the Privacy Shield list.
Google Login API	Marketing	California, US	A Google Account is a user account that is required for access, authentication and authorization to certain online Google services, including Gmail and similar products. It is a public API and service provided by Google Inc. Google utilizes the personal data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google service. We use Google Login API for the fast registration process.
Google Optimize	Marketing/Analytics	California, US	Google Optimize (Optimize) is an experimentation tool developed by Google. Optimize utilizes Google Analytics cookies to target content variants to a user and a content experiment cookie to determine a user’s participation in an experiment. We are using this tool to record and track visitors involvement in a website experiment such as an A/B Test where half of our website users see one webpage, and the other half see another custom variant. These tests help us improve the user experience.
Google Tag Manager	Marketing/Analytics	California, US	Google Tag Manager is a tag management system created by Google to manage JavaScript and HTML tags used for tracking and analytics on websites. We use this service to load scripts into our webpages. These scripts can have tracking or advertising purposes which are also mentioned in this Privacy Policy.
Hotjar	Marketing/Analytics	Malta, EU	Hotjar is a tool that reveals the online behavior and voice of our users. By combining analysis and feedback tools, Hotjar gives us an idea of how to improve our platform. For more information refer to the Hotjar privacy policy.
Instagram	Marketing	California, US	Instagram is a photo and video-sharing social networking service owned by Facebook, Inc. The user can share any listing or anything on Instagram based on the feature that offered in the platform. For public accounts anyone on Instagram can see the user story, while for private accounts only approved followers can see stories. Whenever we use the services of Instagram the Instagram privacy policy applies. For further Information refer to this thread.
Mailchimp	Mass Messaging	Georgia, US	We use Mailchimp to send promotional emails to our users. We share your name and email address with Mailchimp. Whenever we use the services of Mailchimp the Mailchimp privacy policy applies. Included in the Privacy Shield list.
Mailgun	Mass Messaging	California, US	We use Mailgun to send transactional emails to our users. We share different types of personal data with Mailgun depending on what kind of message we send. Whenever we use the services of Mailgun the Mailgun privacy policy applies. Included in the Privacy Shield list.
MessageBird	Mass Messaging	The Netherlands, EU	We use MessageBird to send text messages (SMS) and emails to our users. We share your phone number, email address and SMS content with MessageBird. The SMS content could contain personal information to directly address you (e.g. name). Whenever we use the services of MessageBird the MessageBird privacy policy applies. Is established in the EU and thus needs to comply with the Relevant Legislation.
Mixpanel	Marketing/Analytics	California, US	Mixpanel is a business analytics service company. It tracks user interactions with web and mobile applications and provides tools for targeted communication with them. Its tool-set contains in-app A/B tests and user survey forms. Data collected is used to build custom reports and measure user engagement and retention. Ticketswap use Mixpanel for better reporting and user analysis. Privacy Policy of Mixpanel
Mollie	Payments Only for EUR payments	The Netherlands, EU	In performing its services, Mollie acts as a Data Processor for TicketSwap. As a payment services provider, Mollie however also has own obligations with regard to your personal data. Mollie can therefore also be regarded as a Data Controller with regard to your personal data. For any data processing operations Mollie performs as a data controller, Mollie’s privacy policy applies. Is established in the EU and thus needs to comply with the Relevant Legislation.
Przelewy24 (“P24”)	Payments Only for PLN payments	Poland, EU	In performing its services, P24 acts as a Data Processor for TicketSwap. As a payment services provider, P24 however also has own obligations with regard to your personal data. P24 can therefore also be regarded as a Data Controller with regard to your personal data. For any data processing operations P24 performs as a data controller, P24 privacy policy applies. See for more information also the GDPR Information page. Is established in the EU and thus needs to comply with the Relevant Legislation.
Secureswap	Mass Messaging	The Netherlands, EU	For our SecureSwap service we have partnered up with various ticket providers. We have entered into data processing agreements with those ticket providers, as to safeguard your personal data as much as possible. Refer to here for the full list of partnered ticket providers and organizers. Is established in the EU and thus needs to comply with the Relevant Legislation.
Segment	Marketing/Analytics	California, US	Segment is a place to collect customer data and send it to our tools for analytics (e.g. Google Analytics, Firebase) and marketing purposes (e.g. Google Adwords, Facebook Pixel etc.). Essentially Segment is a company that helps us process our customer data. We collect personal data and cookies to identify the users and pushing data to Segment to connect with other 3rdparty products for analytical and marketing purposes. See here for the details. Included in the Privacy Shield list .
Snapchat	Marketing	California, US	Snap Inc. is an American technology and camera company, based in Santa Monica, California. We use Snapchat API to give our users a chance to share their public information on Snapchat. Snapchat Privacy Policy
Stripe	Payments	California, US	In performing its services, Stripe acts as a Data Processor for TicketSwap. As a payment services provider, Stripe however also has its own obligations with regard to your personal data. Stripe can therefore also be regarded as a Data Controller with regard to your personal data. For any data processing operations Stripe performs as a data controller, Stripe’s privacy policy applies. When processing payments or payouts we may use Stripe to process payments made to us and to other users. In such event your payment information will be transmitted to Stripe via an encrypted connection. Stripe uses and processes your payment information, such as bank account number in accordance with Stripe’s privacy policy. We only store tokenized data in connection with the processing of payments (incl. last 4 digits credit card number) ourselves. Included in the Privacy Shield list.
TransferWise	Payouts	United Kingdom, EU	TransferWise processes payouts to Sellers in a selected number of countries* in Central Eastern Europe. We send your bank account holder name, IBAN and date of birth to TransferWise to execute the payout. Whenever you are receiving payouts as a Seller in the aforementioned countries the TransferWise privacy policy applies. *refer to FAQ item about payouts.