VIBEAPP PRIVACY POLICY
1. INTRODUCTION

1.1 The privacy and protection of your personal data is very important to Ticketscloud, Inc. (hereinafter referred to as “the Company”). Our aim is to provide you with reliable and secure services by treating your personal data respectfully and letting you have control over it.

1.2 Please read this Privacy Policy carefully before using the platform or the application or registering to use our services in the Vibeapp as it includes important information regarding your Personal Data and other information.

1.3 Together with the Terms of Service and the Agreement between the Organiser and the Ticket System, this Privacy Policy sets forth our philosophy and methods concerning the personal data provided to us and how we use, process and treat it.

2. PRIVACY STATEMENT

2.1 Application. This Privacy Policy sets forth our policy with respect to personal information, i.e. the information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (hereinafter referred to as “Personal Data”) that is collected from the Ticket Purchasers, the Organisers, the Ticket Systems and the Distributors on or through the Platform and its Services (including the Vibe). “Non-Personal Data” as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person.

2.2 Purposes for Personal Data processing. We process the collected Personal Data in order to enable you to use our Services and all the opportunities provided by our Platform or otherwise provided by us (including our application programming interfaces), and all of the applications and digital and blockchain solutions offered, maintained and provided by the Company. We do not sell your Personal Data.

2.3 Non-Personal Data. When you interact with the Platform and its Services, we may also collect Non-Personal Data. The limitations and requirements in this Privacy Policy upon our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.

2.4 Your data controller and data processors. In virtue of processing personal data of the Ticket Purchasers carried out in order to render of the Services, the Company shall be deemed a data controller. The Organisers, the Distributors, the Ticket Systems, the Ticket Purchasers, as well as our business partners, processing the personal data of Ticket Purchasers on behalf of the Company shall be deemed data processors. The Company as the data controller takes necessary steps to ensure that all processing of your Personal Data by us and by our partners (being data processors) is lawful. The lawful basis for the processing of your personal information shall depend on the purposes for which we process your data.

2.5 Conformity with the legislation. Any information you provide to us will be treated in accordance with this Privacy Policy and the applicable legislation of the data controller’s countries, depending on where you reside as follows:

All countries in the European Union — the EU General Data Protection Regulation (hereinafter referred to as “the GDPR”) and the UK Data Protection Act 2018: TICKETSCLOUD LTD, with its registered office address: C/O Ja Associates 1-4 The Parade, Monarch Way, Ilford, Essex, United Kingdom, IG2 7HT.

The Russian Federation — Federal Law of the Russian Federation “On Personal Data” No. 152-FZ as of 27 July 2006 (hereinafter referred to as “the 152-FZ”),: Ticketscloud LLC, registered under Primary State Registration Number (OGRN) 1187746558560, with its registered office address:Russian Federation, 127015, Moscow, st. Bolshaya Novodmitrovskaya, 36, building 1, room V, We are kindly asking our Ticket Purchasers from Russia to get familiarised with our Privacy Policy in Russian language («ПОЛИТИКА КОНФИДЕНЦИАЛЬНОСТИ ВАЙБ») containing all the essential conditions of application of this policy in the territory of the Russian Federation.

All other countries — The California Consumer Privacy Act (hereinafter referred to as “the CCPA”): Ticketscloud, Inc., with its registered office address: 21515 Hawthorne blvd ste 450, Torrance, CA, 21515, United States.

2.6 The Company as a data controller is entitled to transfer data to other members of the Ticketscloud corporate family.

3. TYPES OF INFORMATION THAT WE COLLECT

3.1 We collect information both online and offline, which includes collecting information on our Platform. The online system represented by the mobile application, developed by the Company for the purchase, handling, processing, storing and settlement of tickets and internal tokens of the system (hereinafter referred to as “Vibeapp” ) and an application programming interface (hereinafter referred to as “API” ), as well as including but not limited to a unique blockchain ecosystem, which includes the program code generated by the system and an application programming interface, as well as including but not limited to our programming solutions, digital pipeline and tools, which all together form the ecosystem designed to interact with Organisers, Distributors, Brokers, Ticket Systems and Ticket Purchasers with the integration of software platforms for payments (hereinafter referred to as “Platform” ) . The collection of information also includes phone or email interactions you have with us.

3.2 When you use or interact with us through the Platform, the Vibeapp and its Services, we may collect personal data, as further described below:

3.2.1 Contact details. We may collect such information as but not limited to name, address, phone number, email, etc.

3.2.2 Payment and billing details. We may collect such information as but not limited to your credit/debit card number and postcode when you buy a ticket.

3.2.3 Information you post. For example, we collect information you post in a public space on our Platform and the Vibeapp, including the offers in our ticket marketplace; an image (your photo) that you uploaded to Platform and Vibapp; information about your contacts (contact list).

3.2.4 Demographic data. We may collect information like your age range or gender. We may collect information about events you like or products you buy. We may collect this as part of a survey, for example.

3.2.5 Other information. If you use our Platform and the Vibeapp, we may collect information about the browser you are using. We may collect information about your location including your precise location. We may collect this using technology such as GPS and Wi-Fi. We may also collect the type of mobile device you are using, or the version of the operating system your computer or device is running. We may look at how often you use the app and from where you downloaded it.

4. MEANS OF COLLECTION OF INFORMATION

4.1 Registration is required to use the Platform, the Vibeapp and the Services. We collect the information in the ways as further described below:

4.1.1 We collect information you provide to us. In case you register on the Platform and the Vibeapp you participate in the activities, i.e. sale, resale, advertisement, distribution and purchase of tickets.

4.1.2 We collect information via cookies. We use tracking tools like browser cookies.

5. USE AND DISCLOSURE OF INFORMATION

5.1 Personal Data retention period. The Personal Data retention period depends on the purposes for which we use Personal Data. We keep Personal Data of our customers as long as is necessary for those purposes. In case your account is terminated by either you or us, we will retain your Personal Data for a term of up to seven years after such a termination (unless a longer period is set forth by legislation) for the purposes of replying to legal controversies and/or regulatory requests or investigations.

5.2 We keep information to resolve disputes, enforce our agreements and as further described below:

5.2.1 We use information to respond to your requests or questions. We may use your information to confirm your registration on the Platform. You may contact us at [email protected] to ask us to access, amend, delete or restrict access to your information according to pp. 8.1.1. – 8.1.4. of this policy.

5.2.2 We use information to improve our products and services. We may use your information to customise your experience with us. This could include displaying content based upon your preferences.

5.2.3 We use information to look at Platform trends and customer interests. We may use your information to make the Platform and the Services better. We may combine information we get from you with the information about you, which we legitimately get from third parties.

5.2.4 We use information for security purposes. We may use information to protect our company, our Ticket Purchasers, or our Platform.

5.2.5 We use information for marketing purposes. We may send you information about special promotions or offers. We may also tell you about new features or products. These may be our own offers or products, or third-party offers or products we think you may find interesting. Or, for example, if you buy tickets from us we will enrol you in our newsletter. You are entitled to opt out from our marketing and promotional emails and newsletters at any time according to p. 8.1.6. of this policy.

5.2.6 We use information to send you transactional communications. We may send you emails, SMS, push notifications in messengers about your account or a ticket purchase. We may also contact you about this policy or our Platform terms.

5.2.7 We use the information to provide high quality service and customer convenience. We may use information about your contacts (contact list) to make it easy for you the use of event ticket donation feature (allowing you to select a phone number from your contact list to donate a ticket to a person). We may use your profile image (your photo), which was uploaded by you to our Platform or Vibapp, as your avatar (profile picture) in the service: to display when communicating in chat, as well as when communicating with other users in the dating service.

5.3 Lawfulness of use of personal data. The Company as the data controller takes necessary steps to ensure that all processing of your Personal Data by us and by our partners (being data processors) is lawful. The lawful basis for the processing of your personal information will depend on the purposes for which we process your information.

6. SHARING OF INFORMATION WITH THIRD PARTIES

6.1 Based on the consent you are giving us, we are entitled to share information with the companies within the EEA for Ticket Purchasers from the EU, and within the USA for Ticket Purchasers from the USA as well as outside of these jurisdictions provided that all our sharing of information is subject to strict control and inner regulations by the Company in accordance with the GDPR and the CCPA respectively, as further described below:

6.1.1 We will share information with third parties who perform services on our behalf (including our subsidiaries and affiliated companies). For example, we share information with the Organisers, the Distributors, the Ticket Purchasers, the Ticket Systems and also with the payment platforms, which helps us manage our online payments process and which fulfils the purchases.

6.1.2 We will share information with our business partners. Our partners use the information we give them as described in their privacy policies, which may include sending you marketing communications. You should read those policies to learn how they treat your information. Please take into consideration that it is our exclusive policy to specify our partners, with whom we are sharing Personal Data. Nevertheless, we only share limited personal data with our partners.

6.1.3 We may share information if we think we have to in order to comply with the law or to protect ourselves. We may share information to respond to a court order or subpoena. We may also share information if requested by a government agency or investigatory body. Or, we may also share information when we are investigating potential fraud and/or misrepresentation.

6.1.4 We may share information with analytics and search engine providers which helps improve search engine optimisation;

6.2 The Company does not share the legal property of tickets between Distributors and Ticket Purchasers.

7. CONTACTING US AND MAKING A COMPLAINT

7.1 If you have requests regarding your Personal Data or you would like to change the way we handle it, please contact us via [email protected]. Please take into consideration that we will respond to your requests at the earliest possible date, unless your request contains irrelevant information, and/or excessive or repeated demands. Hence, we kindly ask you to consider your request duly before you submit it.

7.2 In order to proceed your requests, we may ask for proof of your identity and sufficient personal details about you. Please note that we can only provide you with your own Personal Data, not the Personal Data of any other persons.

7.3 In case you are not satisfied with our reply to your request or you consider that our processing of your Personal Data does not comply with the General Data Protection Regulation, you are entitled to make a complaint to the Information Commissioner's Office (ICO), which is the UK's independent body set up to uphold information rights, at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK. Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number, the website is https://ico.org.uk

8. RIGHTS REGARDING PERSONAL DATA AND CONTROL OVER PROVIDED INFORMATION

8.1 The following scope of your rights is composed following the principles and regulations of the GDPR and the CCPA and is aimed at protecting your rights and freedoms regarding your Personal Data:

8.1.1 Access to Personal Data. You are entitled to request our confirmation stating that your Personal Data is being processed, have access to Personal Data and request certain information on how we hold, share or use your Personal Data.

8.1.2 Correction and update of Personal Data. You are entitled to correct the inaccurate Personal Data and/or update incomplete Personal Data. In case of such changes we need to inform third parties, with whom we previously shared your personal information, that such a correction/update request was made.

8.1.3 Deleting Personal Data. You are entitled to have your Personal Data deleted and therefore stop its processing (hence, stopping us from providing you with the Services) in case you withdraw your consent and/or you object to us processing your Personal Data, if we process your Personal Data unlawfully and if your Personal Data is no longer necessary for the original purpose of its collection. In case of such changes we need to inform third parties, with whom we previously shared your personal information, that such a request was made. Please note that we can refuse to delete your Personal Data in case it is processed for certain reasons, including to establish, exercise or defend legal claims. The third parties with whom we previously shared your personal information can also refuse to delete your Personal Data given reasonable legitimate circumstances.

8.1.4 Restriction of processing of Personal Data. You are entitled to restrict the processing of Personal Data in case you reasonably doubt the accuracy of the provided Personal Data (the processing is restricted until we verify the accuracy of Personal Data), if you think that our processing is unlawful (we need to receive your request to restrict its processing), if we no longer need your Personal Data. In accordance with the provisions regarding objection to processing of Personal Data, we are to consider our legitimate interests for processing your Personal Data to which you have objected. In case of such changes we need to inform third parties, with whom we previously shared your information, that such a restriction request was made. These third parties are to restrict the processing of your information.

8.1.5 Portability of Personal Data. You are entitled to request a transmittance of Personal Data we hold to you and/or another controller other than us (i.e. deliver a copy of your Personal Data to you or to a third party).

8.1.6 Objection to processing of Personal Data. You are entitled to object to processing due to your legitimate interests, or if your Personal Data is used for direct marketing. You can opt out of receiving our marketing emails. To stop receiving our promotional emails you can unsubscribe from our marketing newsletters. Even if you opt out of getting marketing messages, we will still send you transactional messages. We will also still contact you about your orders.

8.1.7 Automated decision making and profiling of Personal Data. You are entitled not to be subject to decisions based solely on automated processing of Personal Data, including profiling. We are checking and verifying the processing of your Personal Data, not allowing automatic decisions to infringe your rights. Hence, you are entitled to contest any automated decision we make about you, if you consider it incorrect and/or irrelevant.

9. AGE RESTRICTIONS

9.1 We do not knowingly collect Personal Data from children under the age of sixteen (16). If you are under the age of sixteen (16), please do not submit any Personal Data.

9.2 We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data without their permission.

9.3 If you have reason to believe that a child under the age of sixteen (16) has provided Personal Data to us, please contact us, and we will endeavour to delete that information from our databases.

10. COOKIE POLICY

10.1 Application. This Cookie Policy sets forth our policy with respect to information, including information that can be associated with a specific person and could be used to identify that person (“Personal Data”), that is collected from Ticket Purchasers or Brokers who are private individuals through cookies, pixel tags, local shared objects, web storage and other similar technologies.

10.2 Consent. By using the Services, you are consenting to the use of the technologies described in this Cookie Policy to collect both Personal Data and Non-Personal Data and to the storage of information on your device or web browser as described in this Cookie Policy.

11. CONFIDENTIALITY AND PROTECTION

11.1 We use a secure transmission method to send us the following types of personal data:

11.1.1 primary personal data (such as name and contact details)

11.1.2 identifiers (such as account password)

11.2 We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:

11.2.1 unauthorised access;

11.2.2 improper use or disclosure;

11.2.3 unauthorised modification;

11.2.4 unlawful destruction or accidental loss.

11.3 All our employees and data processors who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors' personal data.

11.4 We ensure that your personal data will not be disclosed to governmental institutions and authorities except if required by law or other regulations.

12. UPDATE TO THIS PRIVACY POLICY

12.1 From time to time we may change our privacy practices. We will notify you of any material changes to this policy as required by law. We will also post an updated copy on our website https://vibeapp.ru/. Please check our website periodically for updates.

12.2 The current version was last updated on 30 July 2022 in accordance with the requirements of the GDPR, the UK Data Protection Act 2018, the CCPA, the Federal Law of the Russian Federation “On Personal Data” No. 152-FZ as of 27 July 2006.

13. CONTACT INFORMATION

13.1 If you have any questions about this Policy or other privacy concerns, you can email us at [email protected]. Please do not include any sensitive information in your email.

Ticketscloud, Inc

21515 Hawthorne blvd ste 450

Torrance, CA, 90503, United States