Invajo Privacy Policy

  1. Introduction

Welcome to Invajo! This Privacy Policy explains how we use your personal data when providing you with the ability to create, discover, share and book events via our event and booking platform available through our mobile applications, websites and services (”Service”).

Invajo’s platform, websites and domains, including www.invajo.com, and any other webpages, subdomains, country level domain variants that link or refer to this Privacy Policy (collectively, our “Site”), all of the services available on or through the Site or otherwise provided by us (including our application programming interfaces), and all of our mobile applications, (collectively, the “Applications”) are offered, maintained and provided by Invajo. We refer to all of these as our “Services.”

The Service is operated by Invajo International AB, a company incorporated under Swedish law whose principal place of business is at [Grev Turegatan 30, 114 38 Stockholm ].

Through the Services, Invajo provides a simple and quick means for registered users who are event Organizers and/or event administrators (“Organizers”) to create event registration by including the relevant information related to the event, booking info, prices, and other web pages related to their events, to promote those pages and events to visitors or browsers of the Services and to get free or paid bookings, solicit donations and sell merchandise related to those events to users who wish to make bookings, purchases or donations from or to such events (including to free events) (“Attendees”). We refer to Organizers, Attendees and other visitors and browsers of the Services collectively as “Users” or “you.”

This Privacy Policy describes Invajo’s policies and practices regarding its collection and use of 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.

Sometimes we refer to "Non-Personal Data" in this Privacy Policy, by which we mean 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 also 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.

We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

  1. Our principles

We do our best to protect your privacy by using security technology appropriately. This means that:

  1. Personal data that we collect

Collection of personal data

We collect Personal Data about you when you use the Services. This data consists of the information you actively provide us with, and the information which becomes available to us when you use the Service. The Personal Data we may collect includes without limitation your name, address, email address, phone number and other information that enables Users to be personally identified.

We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services. For more on this, see Section 5.

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 Personal Data until such time as it can no longer be associated with you or used to identify you.

We also obtain data by recording your use of the Service. This means, without limitation, that we track how, what and when a User navigates and/or uses specific pages, sections and functionalities of the Service.  This database is accessible only to employees at Invajo, or our third-party partners, who maintain the databases and analyse the data for the purposes described in Section 4.

As an Organizer, we collect some additional Personal Data from you.

As an Attendee, we collect some additional Personal Data from you.

Information you provide to us: If you register for a paid event, we will collect financial information from you (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data.

If an Attendee voluntarily provides personal information in connection with a booking, it will be available to us and will be held by us in accordance with this Privacy Policy. In addition, such information will be delivered 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 Attendees, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.

Your correspondence with Invajo

If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it (such as name, e-mail, phone number, contact information and any personal identifiable information you provide in free text form) and use it to respond to your inquiry; to notify you of publications or other services; or to keep a record of your complaint, question, request, and the like. As always, if you wish to have Invajo “erase” your personal information or otherwise refrain from communicating with you, please contact us at privacy@invajo.com.

Note: if you ask Invajo not to contact you by email at a certain email address, Invajo will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.

  1. How and why we use/process your personal data

Invajo uses your personal data for the main purpose of providing you with the Service. Below you will find a list of sub-purposes, to give you a better and more clear idea of why we process information about you.

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 monitor 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 monitor your ongoing qualification to use such Services.

Personalized Content: The information about your use and preferences is analysed and evaluated to help us understand what kind of services you might be interested in. With the help of this data, your Invajo profile is placed into a certain segment that fits your user behaviour; we will then be able to offer you personalized content based on what segment you are in, i.e. based on what events you like, what functionalities you use, etc.

Communication and Marketing: Where it is in accordance with your marketing preferences and/or use of the Service, we may use your Personal Data to contact you in the future for our marketing 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 personalized content and advertising on or off the Services that we believe might be of interest to you. In particular, Organizers should note that we may use information we receive or collect regarding Attendees (including without limitation via an Organizer’s event registration page) in accordance with the terms of this Privacy Policy, including in the manner set forth above.

Statistics and Service improvement: We may use your Personal Data and other Non-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.

Allowing Organizers to communicate with you: We allow Organizers to use our communication tools, e.g. emails and sms’, to contact Attendees for their upcoming, current and past events, so you may receive communication from our system that originate with such Organizers. If you have made a booking via the Services, your personal and contact information is available to that Organizer. However, Organizers may also import contact information they have from external sources and/or send communications through the Services to those contacts and we will send such communication to those recipients. See “Opt Out from Electronic Communications” below on how to opt out of such communications.

Communicating with you. By providing us with your contact information (phone number, email etc.) we can contact you if there are any issues with the Service. We will also contact you with information about updates in the Service, suggestions to improve and/or adjust event related settings, our newsletter, support issues, etc.


As mentioned above in Section 3, when you correspond with us through any kind of communication, we may retain such correspondence and the information contained in it (such as name, e-mail, phone number, contact information and any personal identifiable information you provide or that is provided automatically by the Service) and use it to respond to your inquiry.

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.

  1. When and how we share information with others

We share your personal data with your consent or as necessary to complete any transaction or provide you with any offers you have claimed.

When you provide payment data to book an event, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

Parent Companies, Subsidiaries and Affiliates: We may share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and/or affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.

Service Providers: For the purpose of providing you with the Service, we need to disclose your Personal Data to our contractors and service providers who process data on behalf of us. For example, but not limited to, suppliers within hosting, backup, database, recovery services, marketing, customer support, communications (email, sms etc.). When we entrust others to process your Personal Data we are responsible for making sure that they are bound with the appropriate contractual terms and this Privacy Policy to protect their actions regarding your shared personal information.

Organizers: When you make a booking via the Service, Personal Data entered by you, other or automatically will be collected by us and the Organizer of the event. As an Organizer you are always responsible for the personal information you collect. This responsibility applies to other persons to whom you grant access to that personal information as well.

Third Party Connections: You can connect your Invajo account to your accounts on third party services (Gmail etc.), 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.]

 

Legal Requirements: We may share your Personal Data if required to do so by law in order for example to respond to any request from law enforcement, a court order or a government agency, or other legal obligation (including in response to public authorities to meet national security or law enforcement requirements), or if we have good reasons to believe that access, use, retention or disclosure of such information is reasonable necessary to:

New owner: If the ownership of some or all parts of Invajo, our Service or other properties and resources will change, the information might be transferred to the new owner.  

  1. Data subject rights

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.

This Privacy Policy is intended to provide you with information about what personal data Invajo collects about you and how it is used. If you have any questions about the policy or the data, please contact us at privacy@invajo.com.

If you wish to confirm that Invajo is processing your personal data, or to have access to some of the Personal Data Invajo may have about you, please contact us at privacy@invajo.com.

You may also at any time write to Invajo Grev Turegatan 30, 114 38 Stockholm. 

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Invajo might have received the data from Invajo; what the source of the information was (if you did not provide it directly to Invajo); and how long it will be stored.

You have a right to correct (rectify) the record of your personal data maintained by Invajo if it is inaccurate. You may request that Invajo erase that data or cease processing it, subject to certain exceptions.

You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Invajo processes your personal data. When technically feasible, Invajo will—at your request—provide your personal data to you or transmit it directly to another controller.

Reasonable access to your personal data will be provided to you at no cost upon request made to Invajo at privacy@invajo.com.

We will consider and respond to all requests in accordance with applicable law.

If access cannot be provided within a reasonable time frame, Invajo will provide you with a date when the information will be provided. If for some reason access is denied, Invajo will provide an explanation as to why access has been denied.

  1. Your Choices

Limit the data you share: 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 open an account, create an event or make bookings, personal contact information will be required.

Invajo Marketing Communications: Invajo may send you electronic communications marketing or advertising for the Services themselves, or events on the Services, to the extent you have registered for the Services or made a booking to an event created on the Services. You can also “opt out” of receiving these electronic communications by using our “Unsubscribe” functionality for such electronic communication. In addition, you may also manage your contact information by logging in (or signing up and then logging in), and manage your settings or if it is event related information, contact the Organizer or, if applicable, use the self service update in the booking confirmation page.

Communications from Organizer: Organizers may use our communication tools to send electronic communications to contacts, including Attendees who have made bookings for their events. Although these electronic communications are sent through our system, Invajo does not determine the content or the recipients of these electronic communications. Organizers are required to use our tools only in accordance with all applicable laws.

When booking: Personal Data is collected when you make a booking. In case you have questions about such information, want to adjust or delete any such information, always contact the Organizer of that specific event.

Don’t complete a booking if you don’t trust the Organizer or for any other reason don’t want to add personal information required for that specific booking.

In order to provide transparency regarding that your personal information will be managed by both the Organizer and Invajo, all bookings made in the Service that relates to you as a User, will be gathered, displayed, reachable and (if applicable) editable under a separate section in the Service.

If Personal Data is collected by Invajo (and not an Organizer via an event), please contact us at
privacy@invajo.com if you have any questions about the data processing.

 

  1. Security of your information

To help protect the privacy of data and personally identifiable information you transmit through use of the Service, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

  1. Data storage and retention

Personal data handled by Invajo is stored and processed in the region in which you live, or in other countries where Invajo, its affiliates, subsidiaries, partners or suppliers are active. We take steps to ensure that the information we collect in accordance with this Policy is dealt with in accordance with the provisions of this Policy and in accordance with applicable laws where the information is available.

If we were to transfer your personal data to third countries, i.e. countries outside the EU/ EEA, we will enter into agreements and take other measures in accordance with applicable legal requirements.

Invajo retains Personal Data for the purposes mentioned in Section 4 and stores this data as long as you are registered to use the Services. You may close your account via the Service or 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.

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact the Organizer of the specific event to which your data relates. For other matters regarding personal information, contact Invajo via privacy@invajo.com

  1. Exclusions

Aggregated data: Aggregated data is collected and processed to monitor and evaluate user trends concerning the Service. This means that information about your booking, interaction and navigation history is collected and then anonymised in a way that means we cannot link the information back to you any longer. We use this anonymous information about how our users use our services for statistics, service improvement and product development of the Service. This data will be completely anonymous and does not constitute personal data. It may therefore be stored a longer time than your personal information.

Anonymization means that data once was  personal information is stripped away of anything that may connect it to an individual, as well as being severed from anything that in the future might make it possible to reconnect this data to an individual. This depersonalisation treatment of data is one step further than the process of pseudonymisation, which means keeping certain information apart, to make it harder to identify an individual using this data. Invajo will anonymize Personal Data after 12 months.

Third Party Links: This Privacy Policy does not apply to any Personal Data that you provide directly to another User or visitor through the Services, including information posted by you to any public areas of the Services. For your relationship with the Organizer, the Organizer’s terms of service or terms of its loyalty program applies. 

Children: Invajo 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 via privacy@invajo.com, and we will endeavor to delete that information from our databases.

  1. Changes and updates to the Privacy Policy

As the Service and our business may change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy at our website. Where required by law, Invajo may provide you with additional notice of such updates, such as via email, phone number or with in-Service notifications. Updates will be effective upon publication on our Website or as required by law, fourteen (14) 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. When the Policy is updated, the latest update date is shown at the top of

the Policy and the changes are described on the Change History page. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any updates to this Privacy Policy constitutes acceptance of those updates. If any updates to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

You should check our website frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it.

  1. Questions, concerns or complaints

Responsible for users of our Service lies with:

Invajo International AB,

        Grev Turegatan 30, 114 38 Stockholm

        info@invajo.com

The responsibility for a specific event lies with the applicable Organizer and we refer your questions, concerns and request to them. You may find their contact information on their Organizer page.

To ask questions or comment about our Policy and our privacy practices att:

        Invajo International AB,

        Grev Turegatan 30, 114 38 Stockholm

        privacy@invajo.com

We will take reasonable steps to work with you to attempt to resolve your complaint.

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CHANGE HISTORY

May 2018: Clarifications due to the entry into force of the new Data Protection

Regulation (“GDPR”) on May 25, 2018. The updated Policy will automatically enter into

force for all existing customers and visitors on May 25, 2018. Your continued use of our

Website from that date will be subject to the new Policy. The Policy has also been

revised to be concise, clear, comprehensible, and easier to understand.