Effective date: May 25, 2018
Brown Paper Tickets is committed to transparency in regard to how we treat personal and business information that is collected through our ticketing and registration platform.
Brown Paper Tickets
When this policy mentions "Brown Paper Tickets," "we," "us," or "our," it refers to the Brown Paper Tickets, LLC. Brown Paper Tickets also has a subsidiary, Brown Paper Tickets LTD, based in the United Kingdom. Contact information as follows:
Brown Paper Tickets, LLC
220 Nickerson St
Seattle, WA 98109
Brown Paper Tickets, LTD
4 Miller Row
Edinburgh EH4 3BQ
Phone: 0800 411 8881
Brown Paper Tickets acts as both a "data processor" and a "data controller". Brown Paper Tickets is a data processor because our service offers a ticketing and registration system for Event Organizers to sell tickets or admission, and collect data about their attendees to admit and communicate with ticket buyers or event attendees. Brown Paper Tickets is a data controller because the information provided by Event Organizers, ticket buyers, and attendees is stored with Brown Paper Tickets to record payment transactions and attendee information.
1. Collection of Personal and Financial Information
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Brown Paper Tickets website and services, create and maintain a trusted and safer environment, and comply with our legal obligations.
Brown Paper Tickets collects your data in two primary ways:
1.1 Information You Provide to Brown Paper Tickets
Some information is necessary to use the Brown Paper Tickets system. The following personal and business information is necessary in order for the Brown Paper Tickets services to work as needed.
- Account Information. When you sign up for a Brown Paper Tickets account, we require certain information such as your email address, first name, last name, telephone number.
- Additional Account and Payment Information. To use certain features of the Brown Paper Tickets system (such as listing an event or purchasing a ticket), we may need additional information, which may include first name, last name, email address, physical address, business name, banking information, credit card information, PayPal information, in order to facilitate the processing of payments.
- Payment Transaction Information. Brown Paper Tickets collects information related to your payment transactions processed through the Brown Paper Tickets website, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the services you've agreed to when using the Brown Paper Tickets website and services.
1.2 Information We Automatically Collect from Your Use of the Brown Paper Tickets Website and Services
When you visit the Brown Paper Tickets website and use the Brown Paper Tickets services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the Brown Paper Tickets ticketing and registration system.
- Geo-location Information. When you visit the Brown Paper Tickets website, we may collect information about your approximate location as determined through data such as your IP address or mobile device's GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu.
- Usage Information. We collect information about your interactions with the Brown Paper Tickets webpages or content you view, your searches for events, ticket purchases or registrations, and other actions on the Brown Paper Tickets website.
2. How We Use the Information Brown Paper Tickets Collects
2.1 Provide, Improve, and Develop Ticketing and Registration Services on the Brown Paper Tickets Website
- Enable you to access and use the Brown Paper Tickets website and services.
- Enable you to list events and sell tickets or registrations.
- Purchase tickets or register for events.
- Operate, protect, improve, and optimize the Brown Paper Tickets experience.
- Provide customer service.
- Send you event notifications, service or support messages, updates, security alerts, and account notifications.
- Enforce the Payment Terms and other payment policies.
- Comply with legal (including banking) obligations.
2.2 Create and Maintain a Trusted and Secure Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Comply with our legal obligations.
- Resolve any disputes with any of our Members and enforce our agreements with third parties.
3. How We Share Your Information and Disclosure
3.1 With Your Consent
3.2 Event Organizer Public Profiles, Event Listings, and Other Public Information
The Brown Paper Tickets website lets you list events to sell tickets or register attendees. The events you list are viewable by the public, and include information you provide, such as name and contact information, which is visible to your attendees, potential attendees, and the general public. Publicly visible information may be "scraped" or indexed through third party tools or search engines. Brown Paper Tickets does not control the practices of third parties accessing your public-facing information.
3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of Our Rights
Brown Paper Tickets may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law, or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Brown Paper Tickets, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any others to danger or legal liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Brown Paper Tickets, its employees, its Event Organizers or ticket buyers, or the general public.
3.4 Service Providers
Brown Paper Tickets uses a variety of third party service providers to help us provide tools and resources related to listing events and purchasing tickets through the Brown Paper Tickets website.
3.5 Social Media
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address in an anonymized and hashed format to share with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our website or otherwise promote our products and services or the Brown Paper Tickets website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be in your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Brown Paper Tickets. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
3.6 Business Transfers
4. Third Party Partners
The Brown Paper Tickets system may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services ("Third Party Partners"). Brown Paper Tickets does not own or control these Third Party Partners, and when you interact with them, you may be providing information directly to the Third Party Partner. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
5. Your Rights
You may exercise any of the rights described in this section on our Request to Removal Personal Data page. Please note that we may ask you to verify your identity before taking further action on your request, and we will need to keep a record of your request.
5.1 Managing Your Information
You may access and update some of your information through your Brown Paper Tickets account settings. You are responsible for keeping your personal information up-to-date on your Brown Paper Tickets account.
5.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information we have and which you cannot update yourself on your Brown Paper Tickets account.
5.3 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider where it is technically feasible.
5.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary to provide ticketing and registration services for you and to comply with our legal obligations. You have the right to request erasure of your information. Please note that if you request the erasure of your personal information:
- If you have purchased a ticket or registered for an event, Brown Paper Tickets cannot remove your information before the completion of the event for business and fraud prevention purposes.
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Brown Paper Tickets account for fraud or safety reasons, we may retain certain information from that account to prevent the opening of a new Brown Paper Tickets account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Brown Paper Tickets may keep some of your information for tax, legal reporting and auditing obligations.
- Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Brown Paper Tickets website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
5.5 Withdrawing Consent
Where you have provided your consent to the processing of your personal information by Brown Paper Tickets, you may withdraw your consent at any time by changing the information on your account, adjusting your Account settings, or by sending a communication to Brown Paper Tickets specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
6. Global Operations
6.1 EU-US Privacy Shield (application pending)
Under the Privacy Shield Framework, Brown Paper Tickets is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at Brown Paper Tickets, Legal Department, 220 Nickerson St., Seattle, WA 98109 or via email to firstname.lastname@example.org. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or seek assistance from our designated Privacy Shield independent recourse mechanism, the American Arbitration Association: https://www.adr.org/.
7. Information Security
Brown Paper Tickets is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, information access controls and annual PCI-DSS audits. Currently, Brown Paper Tickets is PCI-DSS v3.2 Level 1 certified. You can learn more about the PCI-DSS security standards here: https://www.pcisecuritystandards.org/
If you know or have reason to believe that the information you provided to Brown Paper Tickets has been stolen, misappropriated, or otherwise compromised, please contact us following the instructions in the Contact Us section below.
9. Contact Brown Paper Tickets
Brown Paper Tickets, LLC
220 Nickerson St
Seattle, WA 98109
Brown Paper Tickets LTD
4 Miller Row
Edinburgh EH4 3BQ
Phone: 0800 411 8881