1. Definitions and legal references
Personal Data (or Personal Identification Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data (or Non-personal Identification Information)
Information collected automatically through this Site (or third-party services employed in this Site), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Site, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Site) and the details about the path followed within the Site with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Site who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Site. The Data Controller, unless otherwise specified, is the Owner of this Site.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Site as described in the relative Terms of Service
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
1.1 Legal information
1.2 Incorporation By Reference.
2. Owner, Data Controller and Data Processor
The Tangopolix website and domain tangopolix.com, and all of the webpages, subdomains, and subparts of this website (collectively, the "Site"), all of the services available on or through the Site or otherwise provided by us are offered, maintained and provided by Tangopolix (the “Owner”). Tangopolix is the business name under which Daniel Mera de Agustin, registered as a Sole Trader in the United Kingdom with VAT number GB 259529855, trades as with its place of business at 272 Lymington Avenue, N22 6JN, London.
You can contact Daniel by email
2.1 Tangopolix as a data controller and a data processor
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as "data controllers") and organisations that process personal data on behalf of other organisations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
Tangopolix may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
For example, if you create a Vendor (as defined in the Buyer Agreement) account with us to sell Organiser Products (as defined in the Buyer Agreement), Tangopolix will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Site, which could relate to Vendors or Attendees. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about events we think may be of interest to you.
However, if you register for an event as an Attendee, we will process your Personal Data to help administer that event on behalf of the Vendor (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Vendor target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness of various sales channels, etc.). In these circumstances, Tangopolix merely provides the "tools" for Vendors; Tangopolix does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy of any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Vendor as the data controller, not to Tangopolix.
3. Types of Data collected
Among the types of Data that this Site collects, by itself or through third parties, there are: Personal Data, Usage Data and Cookies.
Unless specified otherwise, all Data requested by this Site is mandatory and failure to provide this Data may make it impossible for this Site to provide its services. In cases where this Site specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Site and confirm that they have the third party's consent to provide the Data to the Owner.
3.1 Personal Data
We may collect Personal Identification Information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, become a Vendor (as defined in Vendor Agreement) and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, gender, date of birth, nationality, address, city,country of residence and Additional Registration Data (as defined in Vendor Agreement). Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
3.2 Usage Data
We may collect Non-personal Identification Information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
3.3 Web browser cookies
4. Mode and place of processing the Data
4.1 Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
4.2 Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
4.4 Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
5. The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
To run and operate our Site
We may need your information display content on the Site correctly.
To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently.
To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
To verify your identity
This information may be used to verify your identity, the validity and/or legality of your transactions and/or whether you qualify to sell Organiser Products through the Site.
To improve our Site
We may use feedback you provide to improve our products and services.
To run a promotion, contest, survey or other Site feature
To send Users information they agreed to receive about topics we think will be of interest to them.
To send periodic emails
We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests.
To monetize our marketing services
Analytics, Access to third-party accounts and Displaying content from external platforms.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
6. Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
6.1 Access to third-party accounts
This type of service allows this Site to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.
- Facebook Login (Facebook, Inc.).
This service allows this Site to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
- Twitter Login (Twitter, Inc.).
This service allows this Site to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
- Google Login (Google Inc.).
This service allows this Site to connect with the User's account on Google Drive, provided by Google, Inc.
6.2 Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Site and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
- Google Maps widget (Google Inc.).
Google Maps is a maps visualization service provided by Google Inc. that allows this Site to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
- YouTube video widget (Google Inc.).
YouTube is a video content visualization service provided by Google Inc. that allows this Site to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
- Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Site to incorporate content of this kind on its pages.
6.3 Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
- Mailjet (SAS Mailjet).
Mailjet is an email address management and message sending service provided by SAS Mailjet.
- Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc..
- OneSignal is a message sending service provided by Lilomi, Inc.
OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments. Depending on the permissions granted to this Site, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User's device. This Site uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones. Different device configurations, or updates to devices, may affect or change how these indicated settings work.
6.4 Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Site, for contacting and being contacted by this Site support service. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
- ManyChat Messenger (ManyChat Inc)
ManyChat is a Facebook Messenger Bot that sends out messages and responds to users automatically. The basic functionality lets you welcome new users, send them content, schedule posts, set up keyword auto-responses (text, pictures, menus), automatically broadcast your RSS feed and much more.
Personal Data collected:Usage data, Cookies data.
6.5 Processing Payments
This type of service allow Users to pay Vendors for their Organiser Products (as defined in the Buyer Agreement).
- PayPal (PayPal Inc.)
PayPal’s main business is the issuance of E-money and the provision of services closely related to the issuance of E-money. PayPal enables you to make payments to and accept payments from third parties.
Personal Data collected:Personal Data, Usage Data, Cookies Data.
- MangoPay (MANGOPAY SA)
MangoPay is a EU Licensed electronic money issuer (EMI) providing end to end payment technology for marketplaces and crowdfunding. The EMI license entitles the Site to escrow Users’ funds in secure and guaranteed e-Wallets and to signal transactions between such e-wallets.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
- Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
- Facebook Analytics (Facebook, Inc.)
The Facebook pixel is an analytics tool that allows the Owner to measure the effectiveness of advertising by understanding the actions people take on the Site. Pixel data can be sued to: make sure your ads are being shown to the right people, build advertising audiences, unlock additional Facebook advertising tools.
6.7 Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Site to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Site. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
- Digital Ocean Droplet (DigitalOcean, LLC)
Droplets are a scalable compute platform with add-on storage, security, and monitoring capabilities to easily run production applications.
7. Sharing your Personal Data
We may share or sell information with third parties for marketing or other purposes. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
8. Electronic newsletters
9. Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.
11. The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
11.1 Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
11.2 How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
12. Additional information about Data collection and processing
12.1 Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Site or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
12.2 Additional information about User's Personal Data
12.3 System logs and maintenance
For operation and maintenance purposes, this Site and any third-party services may collect files that record interaction with this Site (System logs) use other Personal Data (such as the IP Address) for this purpose.
12.4 Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
12.5 How “Do Not Track” requests are handled
This Site does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
13. Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
This document was last updated on May 25th, 2018