SimpleSeats | Privacy Policy

Effective Date: July 23, 2020 Last Updated: July 23, 2020 SimpleSeats, LLC (referred to herein as “SimpleSeats”, “we”, “our”, or “us”) and its affiliates recognizes the importance of protecting the personal information we may collect from customers, users, visitors and any other individual or entity (“Users”, “you”, or “your”). This Privacy Policy applies to data collection and privacy practices of SimpleSeats and when we collect personal information through your use of the website, www.SimpleSeats.com, the mobile application, and other SimpleSeats-related sites, software and mobile applications accessible on or by any top-level SimpleSeats domain owned by us (each, a “Site” and collectively the “Sites”), through our social media pages that we control, through email messages that we may send to you, and when you purchase a ticket(s) (collectively, the “Services”). Please note that this Privacy Policy excludes services that state that they are offered under a different privacy policy. Specifically, our Privacy Policy covers the following topics:

When This Privacy Policy Applies
Website Terms of Use
Information We Collect
Information Collected Related to California Residents
How We Use Information We Collect
Our Legal Basis for Collecting Personal Information
Cookies and Similar Technologies
Your Failure to Provide Personal Information
Our Retention of Your Personal Information
Sharing Personal Information
Sale of Personal Information
Your Privacy Choices
1. Privacy Rights Specific to Californians
2. Rights Specific to European Union Residents
Our Opt-in/Opt-out Policy
Third Party Links
International Transfer
How We Protect Personal Information
Children
Direct Marketing and “Do Not Track” Signals
Changes to this Privacy Policy
How to Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites. For certain Services offered by SimpleSeats, you must be at least 18 years old. If you are a legal resident of the state of Washington, you may not use certain Services. If you have any questions or comments about this Privacy Policy, please submit a request to [email protected] When This Privacy Policy Applies Our Privacy Policy applies to all of the Services offered by SimpleSeats, including its subsidiaries and its affiliates, to our users and other individuals who use our Services or use our Sites. Our Privacy Policy is intended to describe our data collection practices globally and applies unless there is a specific country privacy policy which applies to you. However, because the data protection and privacy laws in some jurisdictions where our hotels and Services are located may restrict our data collection and processing practices, our practices may be more restrictive subject to local laws. Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Sites or Services. For example, this Privacy Policy does not apply to our processing of your Personal Information on behalf of third parties such as companies that offer packaged travel arrangements. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads. Website Terms of Use By accessing or using the Sites in any manner, you also agree to be bound by SimpleSeats’s User Agreement or the User Agreement of any related services (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites. Information We Collect We collect information, including personal information, to provide better Services to all our users and visitors. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata. The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:

If you express an interest in obtaining additional information about our Services, request customer support, use the "Contact Us" or similar features on our Site, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, organization, phone number, or email address, and in some instances, you may elect to provide us with location and address information;
If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;
If you use and interact with our Sites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information under applicable law.

If you provide us or our service providers with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy. If you believe that your Personal Information has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below. Information Collected Related to California Residents During the last twelve (12) months, we have collected the following categories of Personal Information from consumers.

Category	Type of Identifiers We Collect	Collected
Identifiers.	First and last name, postal address, unique personal identifier, online identifier, date of birth, Internet Protocol address, email address, account name.	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, address, telephone number, driver’s license or state identification card number, credit card number, debit card number, or any other financial information.	YES
Protected classification characteristics under California or federal law.	Age, race, citizenship, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).	YES
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
Biometric information.	Video imaging.	YES
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
Geolocation data.	Physical location or movements.	YES
Sensory Data	Audio, visual or similar information	YES
Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from our customers or their agents. For example, payment information for concerts or sporting events tickets that our customers purchase from us.
Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing Services to them.
Directly and indirectly from activity on our website (www.SimpleSeats.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
From social media websites, such as Facebook, Twitter, LinkedIn, YouTube, Instagram, and Pinterest.
From third parties that interact with us in connection with the services we perform.
Directly from our customers if they grant us access to their location.

How We Use Personal Information We Collect We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

To present, operate or improve the Site and Services, including analysis of Site activity;
To inform you about Services and products available from SimpleSeats;
To authorize access to our Sites and Services;
To validate your identity or verify communications from you;
To offer and administer programs;
To customize or tailor your experience of the Services;
To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, prize draws and other offers or promotions, and to deliver pertinent emails;
To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services;
For marketing purposes, including but not limited to, facilitating interest-based advertising, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest to you;
To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews;
To respond to and support users regarding their use of the Sites and Services;
To process applications for employment that you submit through the Sites;
To administer general recordkeeping;
To comply with all applicable legal requirements;
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our users or visitors;
For any other purpose that is disclosed to you at the point of collection of the Personal Information, for any purpose for which you provide your prior consent, or for any other lawful purpose.

We and our service providers may use IP addresses to understand the locations from which our customers, users and visitors are accessing the Services. Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. We will treat any information that we combine with your personal information as Personal Information pursuant to this Privacy Policy. We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by SimpleSeats. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations. To the extent we rely on consent for the processing of your Personal Information, we will seek such consent at the time we collect your personal data. We may also use the Personal Information we obtain about you in other ways for which we provide specific notice at the time of collection. Our Legal Basis for Collecting Personal Information Whenever we collect Personal Information from you, we may do so on the following legal bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
- Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables SimpleSeats to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our visitors, and to better understand how people interact with our Sites;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence.

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes. Cookies and Similar Technologies We and our partners use various technologies to collect and store information when you visit one of our Sites or Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google Analytics, Google Tag Manager, Adjust, Iterable and similar partners. The technologies we use for this automatic data collection may include: Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy. Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Clickstream data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites. Location Data. If you grant us access to your location, SimpleSeats may collect information about your location when you use our Sites and Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application. Your Failure to Provide Personal Information Your provision of Personal Information is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services. Our Retention of Your Personal Information We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). Sharing Personal Information SimpleSeats may disclose your Personal Information to commercial providers for a business purpose, which include verifying your identity when making a payment. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

Identifiers;
California Customer Records Personal Information categories;
Protected Classification characteristics under Californian or federal law;
Commercial information;
Biometric information;
Internet or other network activity information;
Geolocation Data;
Sensory Data;
Inferences drawn from other personal information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

Our affiliates;
Strategic business partners who provide goods, services and offers that enhance your experience at our properties, or that we believe will be of interest to you, such as personalized and unique travel experiences;
Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you;
Service providers and other third parties we use to support our business, including without limitation those performing core services (such as billing, credit card processing, customer support services, customer relationship management, accounting, auditing, processing insurance claims, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services, the processing and fulfillment of your orders, and making certain functionalities available to our users;
Commercial providers;
Broker accounts.

We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of SimpleSeats if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Fulfill any purpose for which you provide it;
Meet any applicable law, regulation, legal process or enforceable governmental request;
Enforce applicable Terms of Use, including investigation of potential violations;
Detect, prevent, or otherwise address fraud, security or technical issues;
Protect against harm to the rights, property, assets or safety of SimpleSeats, our users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of SimpleSeats’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by SimpleSeats about its users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy.
For any other purpose disclosed when you provide the information; and,
When we obtain your consent to do so.
For users of certain Services, your username on the Services and the city in which you registered for the Services may appear in leaderboards that can be viewed by the public on the Services. In addition, certain of your profile information (such as your username, name and/or other information) may be viewed by other users participating in the Service in which you participate. We may include your username, name and/or other information in publicity materials, to the extent permitted under applicable law.

We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. Sale of Personal Information In the preceding twelve (12) months, we have not sold any Personal Information. Your Privacy Choices You may have certain rights relating to your Personal Information, subject to local data protection law. We aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

Privacy Rights Specific to California Residents Under the California Consumer Privacy Act, California residents have specific rights regarding their Personal Information. This section describes Californians’ rights and explains how California residents can exercise those rights. Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
- Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
  - Exercising Your Rights
  - Our Response to Your Request
Privacy Rights Specific to European Union Residents The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
- The right of access. You have the right to request a copy of your Personal Information which we hold about you.
- The right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
- The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Information for a specific purpose.
- The right to be forgotten. You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
- The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
- The right to data portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here: www.ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
- Changing or Deleting Your Information. All customers may update or correct information about yourself by making changes to your profile, or emailing us at [email protected]. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

Our Opt-in/Opt-out Policy By providing an email address on the SimpleSeats Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information. For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be. We currently provide the following opt-out opportunities:

At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a SimpleSeats Partner to unsubscribe from the service.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service-related notices. Third Party Links The Sites may contain links to webpages operated by parties other than SimpleSeats. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. SimpleSeats strongly recommends that each User review the third party's terms and policies. International Transfer We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites. How We Protect Personal Information SimpleSeats maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information. SimpleSeats collects account information for payment or credit, and SimpleSeats will use the information only to complete the task for which the account information was offered. Children’s Privacy The Site is not intended for use by children. We do not intentionally gather Personal Information about visitors who are under the age of 16 and, on certain Services, under the age of 18. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 (or 18, for certain Services) in the applicable jurisdiction, please contact us at [email protected]. If we learn that we have inadvertently collected the personal information of a child under 16 (or 18, for certain Services), or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible. Direct Marketing and “Do Not Track” Signals SimpleSeats does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies. California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to [email protected] with the subject heading “California Privacy Rights,” or (b) a letter addressed to SimpleSeats, Attention: Privacy Inquiry, 225 W 34th Street #1708, New York, New York 10122 U.S.A. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph. Privacy Policy Modifications Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review. How to Contact Us If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us: Via e-mail: [email protected] By writing to us: SimpleSeats, LLC Attn: Privacy Policy Inquiry 225 W 34th Street #1708 New York, New York 10122 U.S.A.

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