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Last Updated: June 19, 2024
Introduction ASM Global and its affiliates, subsidiaries, and other parent companies under the various ASM Global brands described below and as may change from time to time (collectively, “Our Group,” “we,” “our,” or “us”) are the operator of, or service provider for, various entertainment and public-assembly facilities (collectively, the “Venues” (defined below)). References to Our Group include (without limitation):
We are committed to respecting your privacy. This Privacy Policy (“Policy”) describes how we collect, process, and share your Personal Data. This Policy describes your rights and choices with respect to your Personal Data (as defined below) and other important information.
Key Points
Outline
Scope of this Policy This Policy applies to your use of our “Services,” which include the following:
Our “Offline Services” Services you use when you visit our Venues in the United States (US) or Canada, purchase a ticket for an event on-site, or otherwise visit a Venue owned, operated, promoted, or serviced by Our Group.
Our “Digital Services” Our products, services, or technology in Venues and events we own or operate; and Our websites, mobile applications, and other online services, including data collected when you interact with or reference our products/services or advertisements online, as well as via social media (e.g., when we correspond with you via social media, when we access information provided by social media platforms in relation to our pages on those platforms, or if you reference or interact with our Venues on social media).
Our “Telephone Services” Services you use when you call our Venues, ASM Global or Our Group; interact with the touch tone service, speak with a representative; or leave a voicemail message. Note that certain third parties may be able to identify you across sites and services using the information they process; however, any such processing not done at the direction of ASM Global is outside the scope of this Policy. For example, if you purchase a ticket to attend an event at an ASM Global Venue but you purchase it through a third party, such as Ticketmaster, your interactions with Ticketmaster are not covered by this Policy. This Privacy Policy provides the following information:
Categories and Sources of Personal Data The following describes how we process data that is linked or reasonably linkable to a particular individual or household (“Personal Data”), including the categories of Personal Data, its sources, and the purposes for which we process that Personal Data.
The categories of Personal Data we process The categories of Personal Data we collect, and use may include (specific data are examples, and may change): Audio/Visual Data - Recordings and images collected from our surveillance cameras when you visit Venues and areas adjacent to them, as well as audio files and records, such as voice mails, call recordings, and the like.
Biometric Data - Fingerprint, iris scan, closed circuit television recording, and other audio/visual data analyzed by facial recognition and other identification systems operated at Venues (if any).
Commercial Data - Information about the Services we provide to you and about transactions you make with Us or other companies for events and services at our Venues (including for example, information about purchases, what has been provided to you, when and where and, if applicable, how much you paid) and similar information.
Contact Data - Identity Data that relates to Information about how we can communicate with you, such as email, phone number, and physical addresses, social media handles, and information you provide to us when you contact us by email or when you communicate with us via social media.
Device/Network Data - Browsing history, search history, and information regarding your interaction with a website, application, or advertisement (e.g., IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, system and application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs and pixel tags.
Financial Data - Information such as bank account details, payment information for products or services purchased.
Government ID Data - Data relating to official government identification, such as driver’s license or passport numbers, social security numbers, etc., including similar Identity Data included in Cal Civ Code § 1798.80(e).
Health Data - Information about your health. For example, when you are buying tickets for wheelchair accessible spaces, when you request a sign language interpreter, when other accessibility requests are made or when we are responding to an accident which may have happened at one of our Venues. Some health data, such as temperature screening checks, may also be processed for health and safety purposes at Venues; such requirements will be clearly posted if they are in place.
Identity Data - Information such as your name; address; email address; telephone number; gender; date of birth, age and/or age range; account login details, e.g., username, avatar, or other account-related information; your identity, public profile, and similar information from social networks such as social media networks; and information such as unique IDs linked to wristbands used for access to our products and services, and information about your vehicle (when you use certain parking facilities).
Inference Data - Personal Data provided by you, social media companies or data aggregators used to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, aptitudes, market segments, likes, favorites and other data or analytics, including interests, household data such as income, number of children, occupation, home ownership status, the products and services you use or intend to use or purchase. We do not, however, use the Personal Data we collect about you to infer Sensitive Personal Information (such as national orgin, race or ethnicity) or use Sensitive Personal Information we may collect to create inferences about you.
Location Data - Information about your location, including “Precise Location Data” (location data within an 1750 foot radius, such as data from GPS, wi-fi triangulation, dates and times of your visit and which parts of our Venues you visited, e.g., entrance location, entrance time, etc. relating to the use of a wristband at Venues and similar) and “General Location Data” (such as social media tags/posts, zip codes, or other general location identifiers such as those linked to an IP address).
Sensitive Personal Information - Some Personal Data is classified as sensitive under privacy laws in the United States and other jurisdictions. This includes Personal Data that reveals racial, national or ethnic origin, status as transgender or nonbinary, status as a victim of a crim, political opinions, religious or philosophical beliefs, or trade union membership, genetic and/or biometric data processed for the purpose of uniquely identifying a natural person, and data concerning health or a person’s sex life or sexual orientation. Some of the Personal Data we collect may qualify as Sensitive Personal Information. That data includes social security, driver’s license, or state identification card numbers; precise location data, account log-ins and passwords; biometric data for the purpose of uniquely identifying a natural person; or data concerning health.
User Content - Unstructured/free-form data that may include any category of Personal Data, e.g., data that you give us in free text fields such as comment boxes, answers you provide when you participate in sweepstakes, contests, votes and surveys, including any other Personal Data which you may provide through or in connection with our Services.
Sources of Personal Data We collect Personal Data from various sources, which vary depending on the context in which we process that Personal Data. Our Services may contain links to other websites, products, or services that we do not own or operate, and we are not responsible for the content provided by, or the privacy practices of, these third parties. For example, if you are using a ticket seller or reseller services or website, your interaction with that service provider is governed by their privacy policy. Please be aware that our Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
This Privacy Policy applies to the Personal Data we collect, and the sources of that Personal Data may include:
Data you provide us - We will receive your Personal Data when you provide it to us, when you purchase our products or services, complete a transaction via our Services, or when you otherwise use our Services.
Data we collect automatically - We may collect Personal Data about or generated by any device you have used to access our Services, the websites or mobile applications of other companies in Our Group, the websites of any ticketing service provider used to purchase a ticket to our Venues, or when you use WiFi at any of our Venues.
Data we receive from Service Providers - We may receive Personal Data from ticket agents (such as Ticketmaster, AXS and others) who transfer Personal Data to us when you purchase a ticket from them for our Venues, and from other service providers performing services on our behalf. Without this sharing of Personal Data, the agents and ASM Global cannot provide the purchased products/services.
Data we receive from promoters and event partners - We may receive Personal Data from event promoters, producers, and other partners or similar parties that provide us information in connection with products and services you purchase from them, or when you express interests (e.g., team preference or mailing list sign up) that relate to Our Group.
Data we receive from aggregators and advertisers - We may receive Personal Data from ad networks, data brokers, behavioral advertising vendors, market research, and social media companies or similar companies who provide us with Personal Data about you and your household, demographics, preferences, etc.
Data we receive from social media companies - We may receive Personal Data from social media companies that transfer Personal Data to us when you register for one of our Services or interact with that social media company on or in connection with our Services or Venues, such as by clicking on an ad for one of our Venues while on the social media app. Your interactions with the social media companies, however, are governed by their Terms of Use and Privacy Policies, not by the ASM Global Privacy Policy.
Data we create or infer - We, certain partners, social media companies, and third parties operating on our behalf, may create and infer Personal Data such as Inference Data or Aggregate Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. We may combine any Personal Data about you that we receive from you, from other companies in Our Group, and from third parties, except that we will not combine any Sensitive Personal Information for the purpose of creating inferences.
How We Process Personal Data When you use our Services, we process your Personal Data in specific contexts and for certain specified purposes, as well as for our general business purposes and, in some cases, for commercial purposes. We describe the purposes and their related contexts below:
How We Collect and Use Personal Data We collect and process Personal Data in several contexts when you use our Services, including: When you make a purchase or other transaction through our Services When you visit our venues Closed Circuit Television (CCTV) at our Venues Biometric Data or other Identify Data for access to certain Venues or areas at certain Venues When you access or use our Digital Services (mobile applications), including through the use of cookies and other tracking technologies When you access or use our Offline Services When you access or use our Telephone Services When you enter and/or win a contest or other promotion connected to ASM Global or one of our Venues When you contact us or submit information to us Feedback and Surveys When we purchase Personal Data for marketing and promotional purposes
See below for more information regarding the context in which we process Personal Data.
When you make a purchase or other transaction through our Service We generally process Identity Data, Financial Data, Commercial Data, Government ID Data, and Contact Data when you engage in a purchase transaction. We process this Personal Data as necessary to perform or initiate a contract with you, process your order and payment, and carry out fulfillment and delivery. In addition, we may also collect or create Device/Network Data and Inference Data. This data, together with other data we collect in this context is used as necessary in connection with certain legitimate business interests, such as: ensuring the security of our Services and to prevent fraud; ensuring you meet age or other contractual requirements related to the purchase; and providing you with information about our Services, to contact you about administrative matters, and to manage and respond to any queries or complaints you make or any correspondence you send us.
We may also use Identity Data, Financial Data, Commercial Data, Contact Data, and Device/Network Data collected in this context for our Commercial Purposes.
When you attend our Venues We generally process Identity Data, Commercial Data, Financial Data, Government ID Data, and Contact Data when you interact with us Offline at our Venues. Additionally, when you use electronic or Radio-frequency identification (RFID) ticketing technologies, or use in-Venue Digital Services, we may collect Device/Network Data (see below for additional information regarding our Digital Services) and Precise Location Data. If you use biometric access or identification technologies, we may collect and use Biometric Data as necessary to grant you access to the Venues and provide the services or products you have purchased. We may process this data in combination with Inference Data and Location Data that we collect and/or create as necessary in connection with certain legitimate business interests in:
In certain cases, we may collect Health Data or Biometric Data. Health Data is generally used so that we can provide you with tailored services (for example, a wheelchair accessible space or a sign language interpreter) or to help us investigate an incident which may have taken place at our Venues. Biometric Data may be collected in connection with biometric access technologies, and is used for access control, creating aggregate data, personalization, or Other Business Purposes. In each case, where consent is required by law, we will process this information only with appropriate consent. We may also use Identity Data, Commercial Data, Contact Data, and Precise Location Data collected in this context for Commercial Purposes.
Closed Circuit Television (CCTV) We may operate CCTV or security cameras on and within view of our Venues. In connection with these systems, we collect and/or create Audio/Visual Data in connection with certain legitimate business interests, such as:
When you access or use our Digital Services When you use our online or in-Venue Digital Services, we may automatically collect and process Device/Network Data. We may use this data as necessary to initiate or fulfill your requests for certain features or functions through our Services, such as keeping you logged in, delivering pages, etc. In addition to Device/Network Data, we may also collect and process (including through the use of cookies and similar technologies) Contact Data, Identity Data, and Inference Data. We typically use this data as necessary in connection with certain legitimate business interests, such as:
Some Digital Services may, with your consent, process Location Data, including Precise Location Data. We use this data, together with Inference Data, and Device/Network Data, in order to determine your proximity to portions of our Venues, provide directions and contextual information to you, and other features that require the use of location. We may also use this information in connection with our legitimate business interests, such as creating aggregate information about users’ location and patterns, which we use to help improve our Venues and other Services. Note, Location Data may be required in order for you to use certain Features of our Digital Services. Precise Location Data will not be used for targeted advertising or sold to other parties.
We may also process Identity Data, Contact Data, and User Content if you interact with or identify us, or relevant promoters, artists, sponsors or other partners on social media platforms. Additionally, Personal Data processed when you submit information to us or complete a purchase or transaction (among others) may involve processing through Digital Services.
We may use Identity Data, Device/Network Data, Location Data (including Precise Location Data), Inference Data, and Contact Data collected through our Digital Services for Commercial Purposes.
Cookies and other tracking technologies We may use cookies and similar technologies on our Digital Services. These technologies can be used to collect or create Identity Data, Device/Network Data, Contact Data, or Inference Data. Third parties may be allowed to view, edit, or set their own cookies or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of our websites, and some of these technologies can be used by us and/or our third-party partners to identify you across platforms, devices, sites, and services. Third parties may engage in targeted advertising using this data.
We and authorized third parties may use cookies and similar technologies for the following purposes:
The use of these technologies by third parties may be subject to their own privacy policies and is not covered by this Policy, except as required by law. We may also use your Identity Data, Device/Network Data, Inference Data, and Contact Data collected in this context for Commercial Purposes.
When you enter a contest or other promotion We may collect and process Identity Data, Contact Data, Government ID Data, Audio/Visual Data, and User Content as necessary to process your request to enter a contest, or take part in a promotion, notify you if you have won, or to process delivery of a prize or for other related purposes.
In addition, we may process this information in connection with our legitimate business interests, such as:
If you win a contest/sweepstakes, we may publicly post some of your data, such as your likeness or image, on our website or mobile application (for example, acceptance of a prize may also require you to allow us to post publicly some of your Personal Data such as on a winners’ page). Where required by law, your information will not be posted without your consent. We use Audio/Visual Data, Contact Data, Identity Data, and User Content information for Commercial Purposes, unless prohibited by law.
When you contact us or submit information to us We may collect and process Identity Data, Contact Data, and User Content as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes. This information is primarily used to respond to your request, and to otherwise fulfill our contract or communicate with you, as appropriate. Additionally, where you consent or if otherwise permitted by law, we may send you marketing communications as described further below, and use this information for Commercial Purposes.
Feedback and Surveys We generally process Identity Data, Contact Data, Inference Data, and User Content collected in connection with guest surveys or questionnaires. We generally process this Personal Data as necessary to respond to guest requests/concerns, create aggregate analytics regarding guest satisfaction, or to allow our third-party partners to communicate with guests. Feedback/Survey data may be made available to certain third-party partners, who may use it for their own purposes. We may also store and analyze feedback for our purposes, for example, to personalize the Services, and help recommend relevant offers or services. We may also use the Identity Data, Contact Data, Inference Data, and User Content collected in this context for Commercial Purposes.
How We Process Personal Data for Business Purposes We and our Service Providers process Personal Data we hold for numerous business purposes, depending on the context of collection, your rights and choices, and our legitimate business interests. For example, we generally process Personal Data for:
Service Provision and Contractual Obligations We process any Personal Data as is necessary to provide our Services, to provide you with the products and services you purchase or request, to authenticate users and their rights to access the Services, as is otherwise necessary to fulfill our contractual obligations to you, and to provide you with the information, features, and services you request. Additionally, we use Personal Data to authenticate your right to access our Venues, deliver products and services, and for other related matters. Similarly, we may use Personal Data as necessary to audit compliance, and log or measure aspects of service delivery (e.g., to document ad impressions).
Internal Processing and Service Improvement We may use any Personal Data we process through our Services as necessary in connection with our legitimate business interests in improving the design of our Service, understanding how our Services are used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging and similar purposes relating our identification of errors and improving the stability of the Service. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to Users, how Users interact with various aspects of our Service, and how our Service performs.
Security and Incident Detection Whether online or off, we work to ensure that our Services are secure. We may process any Personal Data we collect in connection with our legitimate business interest in ensuring that our Venues are secure, in identifying and preventing crime, preventing fraud, and ensuring the safety of our guests. Similarly, we process Personal Data on our Digital Services as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security activities.
Compliance, Health, Safety, Public Interest We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests; for the establishment and defense of legal claims or where we must comply with our legal obligations; to comply with lawful requests from government or law enforcement officials; and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.
Aggregated Data We process Personal Data about our customers and users in order to identify trends, (to create aggregated and anonymized data about our customers/users, buying and spending habits, use of our Services, and other similar information (“Aggregated Data”). We may pass Aggregated Data to the third parties to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.
Personalization We process certain Personal Data as necessary in connection with our legitimate business interest in personalizing our Digital Services. For example, aspects of the Digital Services may be customized to you so that it displays your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Digital Services and other content. This processing may involve the creation and use of Inference Data relating to your preferences.
Other Business Purposes If we process Personal Data in connection with our Service in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g., with respect to your rights and choices) unless otherwise stated at collection. We will process such information in accordance with the notice provided at the time of collection or in a manner that is necessary and proportionate to achieve the operational purpose for which the Personal Data was collected or processed or for another operational purpose that is compatible with the context in which the information was collected.
How We Process Personal Data for Commercial Purposes We and certain third parties process Personal Data we hold for certain Commercial Purposes, depending on the context of collection and your rights and choices. Commercial Purposes include those that are in support of our commercial or economic interests and may overlap with and include our Business Purposes in some instances. Commercial Purposes include but are not limited to:
Consumer Profiles Entertainment is personal, and we are always working to help you have the best in-Venue experience. To understand our customers’ preferences, and better recommend products and services that are personalized to our prior customers, we may create a “Consumer Profile” by linking together and analyzing Personal Data collected in the following contexts:
We may also augment Consumer Profiles with Personal Data that we create or that we receive from Our Group or third parties and may include Personal Data such as information about Services you have used or purchased previously, information about when you have visited our Venues in the past and which events you attended, demographic data and data from your social media profiles. Sensitive Personal Information will not be used for profiles.
We use Consumer Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services. For example, we may analyze the Personal Data of people who have purchased tickets for a particular future event that we promote, operate, provide services for, or that is hosted at one of our Venues, and then compare them with other people in our database. If we identify people in our database who have similar Personal Data to the original purchasers, we may then target marketing about that event to the new people we have identified in our database, for example, by sending direct marketing emails. We may conduct the profiling and send direct marketing emails automatically. We may also use this information for other Commercial or Business Purposes compatible with the context for which the Personal Data was originally collected.
Marketing Communications Consistent with our legitimate business interests, we (or if appropriate, certain third parties) may send you marketing and promotional communications if you sign up for such communications or purchase products or services from us. For example, we may process Contact Data and Identity Data when you opt-in to receive marketing communications via email or SMS. Where allowed, we may also send you these communications without opt-in, for example, you may receive email marketing communications if you register for our Services or for a promotion, or in connection with your communications with or submission of User Content to us. Similarly, we may also collect Device/Network Data and Contact Data so that we can determine whether you have opened an email or otherwise interacted with our communications, and we may generate Inference Data based on these interactions.
Marketing communications may be personalized or customized based on your Consumer Profile. We may also process this Personal Data for targeted advertising. However, where consent to processing is required by law, we will link and process this information for targeted advertising only with appropriate consent.
Targeted Advertising Our Group, and certain third parties operating on or through our Services, may engage in targeted advertising. This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising. These parties may be able to identify you across sites, devices, and over time.
The parties that control the processing of Personal Data for targeted advertising purposes may create or leverage information derived from Personalization, Consumer Profiles, and Marketing Communications. In some cases, these parties may also develop and assess aspects of a Consumer Profile about you to determine whether you are a type of person a company wants to advertise to and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other Inference Data derived from these observations, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services you were shown in an advertisement.
We generally use targeted advertising for the purpose of marketing our Services and third-party goods and services, to send marketing communications, including by creating custom marketing audiences on third-party websites (such as Facebook). We do not use or share Sensitive Personal Information for targeted advertising.
See the section on Cookies and other tracking technologies for information about how to opt-out of targeted advertising.
Data Sales Certain Commercial Processing purposes involve “sales” of data as defined by applicable law. For example, we may “sell” (as defined by applicable law) certain Personal Data when we engage in marketing campaigns with or on behalf of sponsors, conduct targeted advertising, or we may sell or grant access to Personal Data to our marketing partners, artists, promoters, and other advertisers. We do not sell any Sensitive Personal Information.
See the Data Processing: Categories, Sources, and Purposes of Processing Data and Who it is Sold To, Shared or Otherwise Disclosed To section for a list of categories of Personal Data sold. See the section on Data Sales for instructions on how to Opt-Out of the Sale of your Personal Data.
How We Share Personal Data Our Group - In order to streamline certain business operations, improve Service personalization and behavioral marketing, develop products and services that better meet the interests and needs of our customers, and promote information we believe will be of interest to you, we may share your Personal Data with other companies in Our Group, as well as any other current or future affiliated entities, subsidiaries, and parent companies of ASM Global.
Service Providers - In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests and business purposes, we may disclose your Personal Data to service providers who provide certain services or process data on our behalf. For example, we may use cloud-based hosting providers to host our website or may disclose information as part of our own internal operations or Other Business Purposes. See the Data Processing: Categories, Sources, and Purposes of Processing Data and Who it is Sold To, Shared or Otherwise Disclosed To section for a list of categories of Personal Data disclosed to Service Providers.
Social Media Platforms - In order to improve personalization, deliver more relevant advertisements, and develop better products and services, we may disclose certain Personal Data to current or future affiliated entities and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow third parties (such as social media advertisers, ad exchanges, data management platforms, or ad servers) to operate on our Services and process data for targeted advertising. These transfers may be made for Business and Commercial Purposes and in connection with Data Sales. Additionally, if you use any social media plugin, API, or other similar feature, use an event hashtag or similar link, or otherwise interact with us or our Services via social media, we may make your post available on our Services or to the general public. We may share, rebroadcast, or redisplay Personal Data or other information in the post to the extent permitted by the relevant social media service.
Promoters, Artists, Sponsors - Where allowed by law, or with your consent, we may disclose your Personal Data to other trusted third parties, for example, the artists, promoters or sponsors we work with in the presentation of events at our Venues. In certain cases, these parties may use your Personal Data for marketing or promotional purposes by sending you information about related products or services that may be of interest to you. We may share Personal Data with these parties for Business and Commercial Purposes and in connection with Data Sales.
Data Aggregators - In connection with our marketing operations, and subject to your rights and choices, we may disclose certain Personal Data to data aggregators for Commercial Purposes and in connection with Data Sales. These disclosures/sales can help better personalize our Services, the services of third parties, enrich Consumer Profiles and help ensure that you see advertisements that are more relevant to your interests.
Successors - Your Personal Data may be shared if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Lawful Recipients - In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person, or in such other circumstances as may be required or permitted by law. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties, to the extent we are required to do so by law.
How We Retain Your Personal Data We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. This period of retention may be different if required by law, or if we need to retain data to respond to claims, to protect our rights or the rights of a third party. We review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
Your Rights & Choices and Submitting Rights Requests You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the state where you reside, and our obligations under applicable law.
Your Rights To the extent applicable law grants you the right to do so, and subject to any necessary verification, you may have the right to request that we:
Your Choices Marketing Communications
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email or by adjusting the push message settings for the mobile application, or for other communications, by contacting us using the information in the How to Contact Us section. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.
Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. To exercise this option, click here. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalizing or making relevant certain types of advertising, or other services conditioned on your consent or choice not to opt-out.
Location Preferences
You may control or limit location data that we collect through our Services by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use to interact with our Services. However, please note that use of RFID technologies may be necessary for you to access certain Venues, and the functioning of hardware required for certain processing of Personal Data. Note, general location data may still be collected if you opt-out of specific location services.
Regional Rights
See your state-specific section for additional information regarding data sale opt-out verification, and which privacy choices are available for your state.
Submitting a Rights Request To submit a rights request, complete the request form here or call our toll-free line at 1-844-919-1983. Depending on the type of request you are submitting, you will be asked for certain information, such as your name, the email address we have on file for you, and the Venue(s) you are referencing to enable us to locate the correct data to fulfill the request. In order to protect the privacy and security of the data, you may be asked for additional information, such as a phone number, address, or other data we have on file, to verify your identity. If an authorized agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf, as described in the next section.
We reserve the right to charge a reasonable fee for, or decline to process, requests from a Consumer that are manifestly unfounded, excessive, or repetitive.
Authorized Agents If you are submitting a Rights Request as an “authorized agent” for another individual, you must meet the standards required in that individual’s state of residency to establish your authority. Depending on the request type, we may take additional steps, including requesting written authorization and contacting the individual directly, to verify your authority as their agent. If you fail to meet the requirements or provide the needed information, the request will be denied. Complete the request here and mark the “Authorized Agent” option under “I am an a/an”.
Opting Out of Sale If you are a California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah or Virginia Resident, or otherwise have the right to opt-out of data sales, you can Opt Out of Sale by visiting our Privacy Request page and completing the privacy request form or by calling us toll-free at 1-844-919-1983. You may opt-out of selling of your personal data by clicking on the “Do Not Sell or Share My Info” link on the footer of our website. We may deny requests that we determine in good faith and with reasonable cause to be fraudulent.
Opting out of Sharing for Targeted Advertising You may opt-out of sharing your personal data by clicking on the “Do Not Sell or Share My Info” link on the footer of our website. For some websites, you may also turn off “Marketing” cookies to opt-out of targeted advertising.
Global Privacy Control You can use a browser control such as the Global Privacy Control (GPC) to turn off cookies on some of our websites that collect your Personal Data for the purpose of sharing it for targeted advertising or sale. Websites that recognize the Global Privacy Control will honor the opt-out signal sent by your device. To learn more about how to implement a browser control to send a privacy signal click here.
How We Protect Your Personal Data We use industry standard technical and organizational security measures to protect your Personal Data. We cannot guarantee the security of your Personal Data when you transmit it to us, and any such transmission is at your own risk. Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Third Party Websites and Mobile Applications We are not responsible for the privacy policies, content or security of any linked third-party websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit. In some instances, a third party may operate or host a contest/sweepstakes on our websites or mobile applications and collect your Personal Data. In those cases, where we are not the operator or host of the contest/sweepstakes, we have no control over the Personal Data collected and accordingly urge you to review the third party’s privacy policy before participating.
Minors Our Services are neither directed at nor intended for use by children under the age of 16 in the US. We generally collect information relating to minors only from parents or with parental consent and do not knowingly collect Personal Data from such minors directly. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian. Minors’ images and likenesses may be collected via CCTV footage as part of the provision of security at Venues. These security practices enable the Venues to present events safely and do not target minors. Notices regarding any recording are posted on site at the Venues, and ticket purchasers and ticket holders’ consent to this collection when they purchase or use tickets and/or enter the Venues.
Data Processing: Categories, Sources and Purposes of Processing Data and Who it is Sold To, Shared or Otherwise Disclosed To
Audio/Visual Data
Biometric Data
Commercial Data
Contact Data
Device/Network Data
Financial Data
Government ID Data
Health Data
Identity Data
Inference Data
Location Data
Sources of Info: From you; Automatic Collection; Service Providers; Data we create/infer Purposes: Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance, health, safety, public interest; Aggregated data; Personalization; Other Business Purposes; (2) Personalization & Customer Profiles; Marketing Communications Sold: Social Media Platforms; Promoters, Artists, Sponsors; Data Aggregators Shared for Targeted Advertising: Social Media Platforms; Promoters, Artists, Sponsors; Data Aggregators Other Disclosures: Our Group; Service Providers; Successors; Lawful Recipients
Sensitive Personal Information
User Content
Additional Rights and Disclosures by State Additional Privacy Rights and Disclosures: California Under the California Consumer Privacy Act (“CCPA”) and other California laws, California residents may have the following rights in addition to those set forth in the Rights & Choices section above, subject to your submission of an appropriately verified request. You can learn more about how to submit a data rights request by going to the Submission of Requests section:
Right to Know - You may request any of the following, for the 12 month period preceding your request: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
Right to Delete - You have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right to Non-Discrimination - You have the right to not receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
Right to Correct - You have the right to correct certain Personal Data that we hold about you, subject to exceptions under applicable law.
Direct Marketing - You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
Opt-Out of Sale or Share - If we engage in sales or sharing of data as defined by applicable law, you may direct us to stop selling, sharing or disclosing Personal Data to third parties for commercial purposes.
Minors’ - To the extent we have actual knowledge that we collect or maintain personal information of a minor under age 16, those minors between the age of 13 and 16 must opt-in to any sales of personal information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales of personal information (as defined under CCPA). All minors have the right to opt-out later at any time. Minors under age 13 may have other rights under the Children’s Online Privacy Protection Act (“COPPA”).
Minors’ User Content - Individuals under the age of 18 in California can delete or remove posts by submitting a Request to Delete their information (following the steps described in Submission of Requests or by contacting us at asmdataprivacy@asmglobal.com). If you have questions about how to remove your posts or if you would like additional assistance with deletion, please use the email contact. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the Services. ASM Global does not use or disclose Sensitive Personal Information other than to provide you the Services and as permitted by California law. ASM Global does not sell or share Sensitive Personal Information for the purpose of cross-context behavioral advertising.
ASM Global does not offer financial incentives associated with our collection, use, or disclosure of your personal information. We collect various categories of personal information when you use our Services. A detailed description of the information ASM Global collects and how we use it is provided above in Sections CATEGORIES AND SOURCES OF PERSONAL DATA and HOW WE PROCESS PERSONAL DATA. Section HOW WE SHARE PERSONAL DATA describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances.
How to exercise your rights If you are a California resident, you may exercise your access, correction, and deletion rights as follows:
Authorized agents: California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to submit written authorization confirming that authority.
Additional Privacy Rights and Disclosures: Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia Under the Colorado Privacy Act (“CPA”), Connecticut’s Data Privacy Act (“CTDPA”), Montana Consumer Data Privacy Act (“MTCHDPA”), Oregon Consumer Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (UCPA) and Virginia’s Consumer Data Protection (“CDPA”) Act, residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia have certain rights around ASM Global’s collection, use, and sharing of their personal data. We collect various categories of personal information when you use our Services. A detailed description of the information ASM Global collects and how we use it is provided above in Sections CATEGORIES AND SOURCES OF PERSONAL DATA and HOW WE PROCESS PERSONAL DATA. Section HOW WE SHARE PERSONAL DATA describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. ASM Global does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. ASM Global may engage in “targeted advertising” as that term is defined in the CPA, UCPA, CTDPA, and CDPA (collectively “these states’ privacy laws”).
If you are a resident of these states, you have the right to: (1) request to know what personal data has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal data; (3) request deletion of your personal data, though exceptions under the these states’ privacy laws and other laws may allow ASM Global to retain and use certain personal data notwithstanding your deletion request; (4) obtain a portable copy of your personal data; and (5) request to opt-out of having your personal data processed for the purposes of targeted advertising, sale (as defined by the State’s applicable law), or profiling (these states define “profiling” as any automated processing of Personal Data to evaluate, analyze, or predict personal aspects related to an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements) where it is used to make decisions that produce legal or similarly significant effects.
You can learn more about how to submit a data rights request by going to the Submitting a Rights Request section.
If you believe our response to your rights request is insufficient, you can appeal our decision by emailing asmdataprivacy@asmglobal.com with the subject line “Appeal a Colorado Privacy Request Decision,” “Appeal a Connecticut Privacy Request Decision,” “Appeal a Texas Privacy Request Decision,” “Appeal a Oregon Privacy Request Decision,” or “Appeal a Virginia Privacy Request Decision,” and we will inform you of our final decision on the appeal within the required timeline set by each state’s law. Please include information relevant to your original request, including your name, the date you sent the request, and the type of request you made, so that we can connect it to your appeal.
Additional Rights and Disclosures: Nevada Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. We collect various categories of personal information when you use our Services. A detailed description of the information ASM Global collects and how we use it is provided above in Sections CATEGORIES AND SOURCES OF PERSONAL DATA and HOW WE PROCESS PERSONAL DATA. Section HOW WE SHARE PERSONAL DATA describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. You can learn more about how to submit a data rights request by going to Submitting a Rights Request section.
Additional Information for Canadian Residents Anytime that your personal information is collected or otherwise used, there is an inherent risk of breach. To mitigate these risks, ASM Global has implemented data protection controls to create a secure environment of your data, both in-transit and while at rest.
Transfer Outside of Canada Your personal information may be transferred outside of Canada. Our corporate headquarters are in the USA. Please be aware that information you provide to us or that we obtain as a result of your use of our services may be collected in your jurisdictions and subsequently transferred to, maintained and/or processed outside of your jurisdiction, including in the United States or another jurisdiction by us or our services providers. Personal information processed and stored in another country may be subject to disclosure or access request by the governments, courts, or law enforcement or regulatory agencies in that country according to its laws. We take reasonable steps to ensure that your personal information will only be used for the purposes mentioned above or communicated to service providers with your consent, except where authorized by law.
Canadian Rights and Disclosures Consent
Wherever possible, ASM Global seeks a person’s consent before collecting their personal information. The form of that consent, either express or implied, might vary depending on the circumstances and the type of information being collected. Consent may be provided directly by the individual or by a representative. Express consent can be given orally, electronically or in writing. While express consent is preferred, implied consent may in some cases be reasonably inferred from a person’s actions or inactions. For example, when an individual provides their name and email address for a ticket purchase, their consent to the use for that purpose is implied. When determining the appropriate form of consent, we also consider the sensitivity of the information, the reasons it is being collected, and what a reasonable person’s expectations would be in the circumstance.
It may not always be possible to obtain a person’s consent before we collect, use, or disclose their information. We may use personal information without your consent if it is: for the same purpose for which the information was originally collected or is consistent with the original purpose.
Your Rights Subject to certain exceptions as prescribed by law, you have the right to access, update, and correct inaccuracies in your personal information and to withdraw your consent to our collection of your personal information. If you request that your information, be corrected due to an inaccuracy and we determine that disputed information is actually correct, we will make a note regarding the disputed accuracy of the information but may not change the information.
We will respond to requests within 30 days and may extend the time by an additional 30 days where needed to conduct consultation or convert the Personal Information into an acceptable format.
To submit a rights request, complete your request via the Privacy Request page here or call our toll-free line at 1-844-919-1983.
Complaints Individuals have the right to complain to the Office of the Privacy Commissioner (see contact details below) if they do not agree with our handling of their privacy request. They may also request that a privacy request be escalated to a secondary level of review within the company if they are dissatisfied with the result. We investigate all privacy complaints/requests.
To contact the Office of the Privacy Commissioner to make a complaint, go to this link or call 1-800-282-1376 (toll-free).
Changes to Our Policy We reserve the right to change our Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your Personal Data. We recommend that you consult this page frequently. Your continued use of our Services shall constitute your acceptance of any revised Policy.
How to Contact Us General Privacy Inquiries If you have any comments or questions about this Policy or our privacy practices, please contact our Data Privacy Team at asmdataprivacy@asmglobal.com or our at mailing address below:
ASM Global Parent, Inc. Attn: Privacy 300 Conshohocken State Rd., Suite 770 West Conshohocken, PA 19428 (USA)
Data Rights Requests To submit a Data Rights Request, please refer to Submitting a Rights Request section. * This Privacy Policy was last updated on June 19, 2024.
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