Concierge Live Privacy Policy
Last Updated: July 1, 2023
Concierge Live Privacy Policy
Last Updated: October 1, 2021
Introduction
This Privacy Policy applies to Concierge Live, LLC ("Concierge Live" or "We"), located at 931 Monroe Drive, NE, Suite 102-579, Atlanta, Georgia, USA, 30306, and the use of any of our Services, including without limitation, the Sites and the Applications (all as defined below). Concierge Live respects your privacy, whether you are a Concierge Live customer, one of our customer’s clients or users, or simply an individual visiting one of our Sites, and we are committed to protecting your privacy through our compliance with this Privacy Policy (“Privacy Policy”). The use of Personal Information (as defined below) collected through our Services shall be limited to the purpose of providing the service for which our Customers have engaged Concierge Live.
This Privacy Policy describes our practices in connection with information that we collect through our domestic and international Sites (collectively, our "Sites"), through our web-based and mobile software applications and services (collectively, our "Applications"), as well as through HTML-formatted email messages that we send to you (collectively, including the Sites and the Applications, our "Services").
This Privacy Policy also applies to information about you that we collect or receive:
· In e-mail, text and other electronic messages between you and Concierge Live.
· Directly through our Customer or Customer third-party services.
Please read this Privacy Policy carefully to understand our policies and practices regarding the collection of information about you, whether via our Sites, Applications, or from other sources, and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Services.
Privacy Classification
This Privacy Policy classifies those accessing and using our Services as one of the following:
· Visitors: Individuals and entities that access and interact with our Sites (for instance, to read about Concierge Live products and services, download a white paper, or sign up for an online demo), as well as those whom we meet or learn about through referral, from third parties or other external sources, are referred to as "Website Visitors" or simply "Visitors." Personally identifiable information pertaining to Visitors subject to this Privacy Policy is maintained in one or more Concierge Live marketing databases and Website analytics and management systems that are physically and logically separate from Concierge Live production systems and databases where Application end-user information is maintained. Concierge Live may use the contact information you provide as a Visitor to send you promotional materials, as further described in this Privacy Policy.
· Customers: Individuals and entities that are Concierge Live’s direct customers (for example, event planners, teams, venues, sales departments and marketing departments), including customer personnel that are assigned a login id and are authorized to access and use our Applications pursuant to an active Concierge Live services agreement or under a temporary evaluation license if available, are referred to as "Customers." Personally identifiable information of Customer personnel associated with their Application accounts is treated as End-User information, and will not be used for any purpose other than providing and supporting our Applications (other than for limited exceptions described in the section below titled "How We Use Information" where applicable). Note that information relating to these same individuals who have visited and interacted with our marketing Sites (for instance, to download a white paper or sign up for an online demo) is treated as Visitor information.
· End-Users: Customers’ business contacts, which may include their own current and prospective customers, members, marketing partners, or other third party contacts that use our Applications to interact with our Customers (for example, individuals that register for an event or are invited to an event organized by a Customer, download an event-related mobile app, or complete an online survey) are referred to as "Application End-Users" or simply "End-Users." Concierge Live does not use personally identifiable information of End-Users for any purpose other than providing and supporting the Applications (other than for limited exceptions described in the section below titled "How We Use Information" where applicable).
Information We Collect and How We Collect It
Concierge Live, and our Customers that use our Applications to organize and manage tickets and events or to provide other services, may collect several types of information from and about End-Users, including:
· "Personal Information" that identifies an End-User as an individual or relates to an identifiable person. For example, this includes name, organization, title, postal address, e-mail address, telephone number, fax number, social media account ID or other identifiers by which End-Users may be contacted online or offline. This also may include information that permits End-Users to purchase products or services from Concierge Live or from our customers through the Applications, such as credit or debit card number, or other payment account number, as well as applicable expiration dates and billing/shipping addresses.
· "Other Information" that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as browser and device information, operating system, device type, system and performance information, app usage data, information collected through cookies, pixel tags and other technologies, general geographic location, demographic information and other information provided by a person, such as dietary preferences, interests, activities, age, gender, education and occupation.
Concierge Live may also collect Personal Information and Other Information from Customers and Website Visitors. In some instances, we may combine Other Information with Personal Information (such as combining a Website Visitor’s name with information we gather about this individual’s use of the Sites). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
We collect this information:
· Directly from individuals when they provide it to us.
· Automatically from End-Users as they use the Applications, or from Website Visitors as they navigate through the Sites, using technologies described in the section below titled "Third Party Advertisers and Analytics." Information collected automatically may include browser and device information, details regarding use of the Services, IP addresses and information collected through cookies, web beacons and other technologies.
· From third party sources, such as public databases, joint marketing partners, and social media platforms. For example, if a Site Visitor elects to connect his social media account to his account for our Sites, certain Personal Information from the social media account will be shared with us, which may include Personal Information that is part of the Visitor’s profile or his friends’ profiles.
Information Provided to Us
The information we collect through our Services may include:
· Information that a person provides when utilizing one of our Services, for instance at the time an End-User registers to attend an event being organized by a Concierge Live customer, uses a web chat function with our sales or support teams, or downloads a mobile software application to the End-User’s iPhone or Android device.
· Information that Website Visitors provide by filling in forms on our Sites. This includes information provided at the time of registering to receive product information or white papers, attend online demos, or access other special content on our Sites. We may also ask Customers or Visitors for information when they enter a contest or promotion sponsored by us.
· Information that Customers and End-Users provide when requesting tickets for a Customer event. This includes records and copies of Customer and End-User correspondence (including e-mail addresses).
· Information that Customers and End-Users provide when receiving technical or customer account support. This includes records and copies of Customer and End-User correspondence (including e-mail addresses).
· Responses to surveys that we might ask Customers, End-Users or Website Visitors to complete for research purposes.
· Details of transactions Customers carry out through our Applications and of the fulfillment of Customer orders.
· Records of search queries on our Services.
Some of our Sites allow Visitors to create or post content on message boards, chat, profile pages and blogs and other services to which Visitors are able to post information and materials. Please note that any information posted or disclosed through these sections of our Sites will become public information and may be available to other Website Visitors and to the general public. We urge caution to anyone deciding to disclose their Personal Information, or any other information, on our Sites. Anyone submitting Personal Information relating to other people to Concierge Live in connection with the Services represents that they have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
For What Purpose Do We Collect Information?
We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:
· To present our Services and their contents.
· To provide End-Users with information, products, or services they request from Concierge Live or our Customers using our Applications, for example by processing ticket requests, enrolling End-Users in programs in which they choose to participate or providing End-Users with mobile application access for a ticket offered by a Customer.
· To manage Application accounts, provide customer service, and process payments for purchases by End-Users.
· To provide Customers with notices about their Concierge Live accounts, including invoices, expiration and renewal notices.
· To notify Customers and End-Users about changes to our Services, any products or services we offer or provide though our Services, our terms and conditions applicable to the Services, or this Privacy Policy.
· To communicate with Customers and Visitors by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies or other third parties.
· To allow Customers and Visitors to participate in online product demos, surveys, and online sweepstakes or contests (including to verify participant eligibility and deliver prizes), access and download materials, and use other interactive features on our Services.
· To better tailor Website experience to Visitors interests, Application experience to End-User or Customer interests, and display content according to user preferences.
· To perform research and analyze use of, or interest in, our products, services or content (or products, services or content offered by others on our Website).
· For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
· As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
· In any other way we may describe when you provide the information.
· To fulfill any other purpose for which you provide it or with your consent.
We may also use contact information of Customers and Visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them. Where required, we will seek and obtain recipients’ express authorization before we send marketing emails. If you do not want us to use your information in this way, please adjust your email preferences on the profile page or by clicking the unsubscribe link provided at the bottom of emails you receive from us. For more information, see the section below titled “How to Opt Out of Marketing Messages and Targeted Advertising.”
How to Opt Out of Marketing Messages and Targeted Advertising
If you do not wish to have your email address/contact information used by us to promote our own and/or any third party’s products or services, you can opt-out by sending an email [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. Please note that this opt-out does not apply to information or emails that are necessary in order to use our Services, including without limitation, the Sites and the Applications.
Furthermore, if you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending email to [email protected]. For this opt-out to function, you must have your browser set to accept browser cookies. Please note that we do not control any third party’s collection or use of your information to serve interest-based advertising; however, these third parties may provide you with ways to choose not to have your information collected or used in this way.
California Privacy Rights
California Civil Code Section 1798.83 permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
Disclosure of Your Information
We may disclose aggregated information about users and the use of our Services, and information that does not identify any individual, without restriction.
If you choose to use our Services to transact business with Customers (for example, request tickets for an event, respond to an online survey, or download a mobile application), any information you provide in connection with that transaction will be transferred to, and under the control of, the Customer. Customers will also have access to information (including Personal Information and Application usage data) related to how End-Users interact with the Applications that they use to organize and manage tickets and entertainment assets and events. Although our own use and disclosure of your information will be in compliance with this Privacy Policy, Concierge Live cannot and does not take responsibility for the privacy practices of Customers.
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
· To our subsidiaries and affiliates for the purposes described in this Privacy Policy, including but not limited to providing Services to our Customers and to End Users. Concierge Live is the party responsible for the management of the jointly-used Personal Information.
· To contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain and support our Services, such as, for example, payment processors, data analytics providers, and data center or Web hosting providers.
· To a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Concierge Live’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Concierge Live about our Website Visitors, Customers and End-Users is among the assets transferred.
· To fulfill the purpose for which information is provided. Here are some examples:
o If End-Users provide an email address when registering for an account, we will use the e-mail address to send the End-User information and announcements relating to that ticket opportunities.
o If End-Users utilize one of our Applications to pay for tickets or fees for other products and services using their credit cards, we will pass the credit card information to payment card processors to validate the payment information and complete the transactions.
· As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, our customers, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
· For any other purpose reasonably necessary and disclosed by us when you provide the information or with your consent.
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services or this Privacy Policy link. The inclusion of a link on the Services or within this Privacy Policy does not imply endorsement of the linked site or service by us or by our affiliates.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, BlackBerry, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the Applications.
What are cookies and how do we use cookies on our Sites?
We may use "cookies" to track your preferences and activities on the Sites. Cookies are small data files transferred to your computer's hard-drive by a website. They keep a record of your preferences making your subsequent visits to the site more efficient. Cookies may store a variety of information, including, the number of times that you access a site, registration information and the number of times that you view a particular page or other item on the site. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies; see your browser's help files for details on how to block cookies, how to know when you have received cookies and how to disable cookies completely. You should note, however, that without cookies, some of the Sites’ functions will not be available, and the user will lose some of the benefits of the Sites.
Accessing, Correcting and Deleting Your Information
Upon request, Concierge Live will provide you with information about whether we hold any of your Personal Information. If you are a registered user of one of our Services, you can review, request deletion, and change your Personal Information and/or email preferences by logging into the Services and visiting your account profile page. For example:
· Users of our application may update or correct their Personal Information, other profile settings and user preferences by using the User Profile within the "My Account" section of the App.
You may also send us an e-mail at [email protected] if you wish to confirm that we are processing your personal data or to request access to, correct or delete any Personal Information that you have provided to us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request within a reasonable timeframe. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Please note that we may need to retain certain personal information for the period of time necessary to fulfill the purposes outlined in this Privacy Policy, including, for example, record keeping purposes, including but not limited to completing any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion), or to comply with applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed. For more information, see the section titled “Information Collected on behalf of our Customers.”
Children Under the Age of 18
Our Services are not intended for children under 18 years of age. We do not directly solicit or collect Personal Information from children under 18. If you are under 18, do not (i) use or provide any information on these Services or on or through any of its features, (ii) register to use any of our Services, (iii) make any purchases through our Services, (iv) use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.
EU-U.S. and Swiss-U.S. Privacy Shield
Concierge Live is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Concierge Live complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Concierge Live is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Concierge Live may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Data Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Information" section below. Please also note that the safety and security of your information also depends on you. Please do not share any passwords that you use to access the Services, including without limitation, the Sites and the Applications, with anyone.
In case we become aware of a data breach, we will report such breach to the appropriate authorities within 72 hours. Furthermore, if the security of any Personal Information is put at risk, then the affected or potentially affected users will also be informed within 72 hours.
Information Collected on behalf of our Customers
Concierge Live collects information under the direction of its Customers and has no direct relationship with the End-User individuals whose Personal Information it processes. If you are an End-User of one of our Customers and would no longer like to be contacted by one of our Customers that use our Service, please contact the Customer that you interact with directly. We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to Concierge Live’s Customer (i.e., the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.
We will retain Personal Information we process on behalf of our Customers for as long as needed to provide services to our Customer. Concierge Live will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For more information on where and how long your Personal Information is stored, and for more information on your rights of erasure and portability, please contact [email protected].
Changes to Our Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate with us and stop using the Services, including without limitation, the Sites and Applications. Your use of any of the Services, including without limitation, the Sites and Applications, after posting of such changes shall constitute your consent to such changes.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
Concierge Live, LLC
Attn: Business Operations
931 Monroe Drive, NE
Suite 102-579
Atlanta, Georgia 30308
Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.