1. We ask that you read this privacy policy (Privacy Policy) carefully as it contains important information on who we are, how and why we collect, store, use and share personal information via on Zuzana, all associated sub-domains, web-apps and mobile apps (Platform), your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
2. Defined terms not defined in this Privacy Policy are defined in the Terms of Use.
3. This Privacy Policy is divided into the following sections:
4. This Platform is operated by Siteways Group BV, trading as Zuzana. We are a software services provider.
5. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA). We are responsible as `controller` of that personal information for the purposes of those laws.
6. This Privacy Policy relates to your use of our Platform.
7. Throughout our Platform, Zuzana or Providers may link to websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party platforms, please consult their privacy policies as appropriate.
8. We collect personal information about you when you access our Platform, register an account with us, contact us, send us feedback, purchase services via our Platform, post material to our Platform and/or complete customer surveys or participate in promotions via our Platform.
9. We collect this personal information from you either directly, such as when you register with us, contact us or purchase services via our Platform or indirectly, such as your browsing activity while you are using our Platform (see `Cookies and other tracking technologies` below).
10. The personal information we collect about you depends on the particular activities carried out through our Platform. This information includes:
11. We use this personal information to:
12. This Platform is not intended for use by anyone under the age of 18 under any circumstances and we do not knowingly collect or use personal information relating to children.
13. When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
14. The legal bases that we may rely on include:
15. For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:
| When information is collected | What information we ask for | How and why we use your information |
|---|---|---|
| When you register with us | Contact details: your name and email address; and Age verification: in the case of Providers, a photo of you holding valid photo identification in high resolution. | We ask for this:
We will keep your contact details until you close your account with us, or we close your account. |
| When Providers purchase a Subscription to upload a Listing via the Platform | Your payment information | We ask for this to create and manage Provider Subscriptions. This will be collected by our third-party payment provider in order to process payments and confirm Fan subscriptions, one-off payments and premium account subscriptions. We rely on our contract with you as the lawful basis for collecting and using your personal information. Your payment information will be shared with our payment services providers Worldline and Pay Safe. For more information on how Worldline and Pay Safe process your personal data, please review the Worldline Privacy Notice and the Pay Safe Privacy Notice. We do not store this information at all. |
| When you use or otherwise access our Platform | Browsing data and preferences in relation to our Platform | We ask for this:
We rely on consent as the lawful basis for collecting and using your personal information. We keep this information for as long as you give consent for us to collect it. For more information on cookies, please see our Cookie Policy. |
| When Providers upload Listings onto the Platform | Content that includes the likeness and images of Providers | We rely on consent as the lawful basis for collecting and using your personal information. |
16. We routinely share Punters browsing habits with our software analytics providers in order to optimise the performance of the Platform and fully enable its functionality.
17. We routinely share Providers:
18. Some of those third-party recipients may be based outside the EEA. For further information including on how we safeguard your personal data when this occurs, see `Transfer of your information out of the EEA`.
19. We will share personal information with law enforcement or other authorities if required by applicable law.
20. We will not share your personal information with any other third-party or for any other purposes.
21. We require Providers to provide:
22. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
23. Our use of your personal information will allow us to provide services to you and will result in your data being shared with our third-party service providers who will then be permitted to contact you for marketing purposes should you provide your consent.
24. We may transfer your personal information to the following which are located outside the European Economic Area (EEA).
25. Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where:
26. These are explained below.
27. We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
28. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
29. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
30. Where there is no adequacy decision, we may transfer your personal data to another country we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
31. The safeguards will usually include using legally-approved standard data protection contract clauses. In relation to transfers to our overseas offices or other companies within our group, the safeguards may instead include legally binding rules and policies which have been approved by the European Commission.
32. In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country where an exception applies under relevant data protection law, for example if you have explicitly consented to the proposed transfer after having been informed of the possible risks or the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request.
33. We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
34. If you would like further information please contact us. We will not otherwise transfer your personal data outside of the area comprising the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
35. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our platform. We use cookies on our platform. These help us recognise you and your device and store some information about your preferences or past actions.
36. For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.
37. We would like to send you information about our services, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, telephone, text message (SMS) or automated call.
38. We would also like to share your information with selected third-parties so that they may send you information about their products and/or services, depending on what you agree with us.
39. We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you make a booking with one of our providers via the platform.
40. If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
41. It may take up to 7 days for this to take place.
42. For more information on your rights in relation to marketing, see `Your rights` below.
43. Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
44. For further information on each of those rights, including the circumstances in which they apply, see Rights of the Individual published by the European Data Protection Supervisor.
45. If you would like to exercise any of those rights, please:
46. We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
47. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
48. We hope that we can resolve any query or concern you raise about our use of your information.
49. You have the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the EEA is the European Data Protection Supervisor who may be contacted online here or by telephone at: +32 2 283 19 00.
50. This Privacy Policy was published and last updated on 12th October 2021.
51. We may change this Privacy Policy from time to time and when we do, we will inform you the next time you access the Platform.
52. Please contact us if you have any questions about this privacy notice or the information, we hold about you or if you would like this Privacy Policy in another format (for example: audio, large print, braille).
