DANCE ISLAND LTD
MASTER PRIVACY POLICY
This Privacy Policy (hereafter referred to as “This
Policy”) outlines the manner in which Dance Island handles the
information and personal data which You have provided to The Company and which
enables Us to be able to effectively manage the relationship which You have
with Dance Island.
This Policy applies to Our Mobile Application, Website,
products and/or services that link to this policy or do not have a separate
privacy policy (hereinafter referred to as Our services). This Policy is
intended to give You a better understanding of the data We collect, the reason
why We collect such data, the manner in which We process this data, the
entities with whom We share the said personal data, Your rights in relation to
the collection, processing and sharing of such data and any other pertinent
matter relating to privacy and security.
Any personal data You will provide or which We already
hold will be processed in line with and in the manner set out in this Privacy
Policy. Any and all information will be provided through the Dance Island
websites (namely https://thedanceisland.com/ or https://tditicketing.com/
hereafter collectively referred to as “The Website”), the designated telephone
numbers or any other means which The Company may make available from time to
time.
By reading This Policy You understand and acknowledge
that Your personal data may be processed in the manner set out in this policy.
If You do not agree with the terms of this Privacy Policy please do not use the
Website or otherwise provide Us with Your Personal Data.
Any references in this Policy to “Dance Island”, “Us”,
“We”, “Our” or “The Company” relate to Dance Island Ltd., a company
incorporated under the Laws of Malta bearing company registration number C100102,
and having its registered address at Odin, Triq Misrah il-Barrieri, Msida,
Malta. All processing of Personal Data performed by the Company as envisaged in
this Privacy Policy shall be carried out in line with:
- The
Maltese Data Protection Act (hereafter referred to as the “DPA” – Chapter
586 of the Laws of Malta) as well as any other subsidiary legislation
issued under the DPA as may be amended from time to time; and
- Regulation
(EU) 2016/679 of The European Parliament And
of The Council of 27 April 2016 On
The Protection of Natural Persons With
Regard to The Processing of Personal Data
And On The Free Movement of Such Data, And Repealing Directive
95/46/EC (General Data
Protection Regulation)” (hereafter referred to as “the Regulation” or “GDPR”).
The DPA and the GDPR shall hereafter be
collectively referred to as the “Data Protection Laws”.
The Company determines the means and purposes of the
processing of Personal Data and therefore acts as the “Data Controller” in
terms of the applicable Data Protection Laws.
DEFINITIONS
Data Controller
“Data Controller” means 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; where the
purposes and means of such processing are determined by Union or Member State
law, the controller or the specific criteria for its nomination may be provided
for by Union or Member State law;
Data Processor
“Data Processor” means a natural or legal person,
public authority, agency or other body which processes personal data on behalf
of the controller;
Mobile Application
“Mobile Application” means the mobile and handheld
device software application named “TDI Ticketing” which is a ticketing
service platform which allows authorised users to sell tickets on behalf of
Dance Island, to Dance Island customers for various kinds of events and similarly
sell certain other products or services.
Personal Data
“Personal Data” means any information that identifies
You individually or relates to an identified or identifiable natural person.
SECURITY
We understand the importance of data security measures
and techniques and strive to ensure that Your data is safe with Us. We have put
in place several measures to protect Your data from unauthorised access to and
alteration as well disclosure and destruction of information.
Dance Island uses 256-bit SSL (Secure Socket Layer)
Digital Encryption to protect Your personal data. It’s one of the most
sophisticated security systems that exist today for the Internet. This is the
same unbreakable technology used by all major banks and financial institutions,
so Your security and privacy are assured. To ensure that the protection We offer
is completely up-to-date, We revise and update these systems on a regular
basis.
PERSONAL DATA PROTECTION
Personal Data held by Us is protected using the
highest industry standard security processes and systems. Our commitment to
protect personal data is not merely through quality and high standards but also
through the best and most efficient application of the law. We are bound to
only process personal data if such processing is based on a genuine and
legitimate reason to do so on the basis of one of the legal grounds established
in the GDPR.
PROCESSING ON THE BASIS OF OUR LEGITIMATE INTERESTS
A legitimate interest exists when We have a business
or commercial reason upon which personal data will be processed. In such a case
We undertake to protect any and all of Your personal data and the manner in
which such data is processed and to ensure that such processing would not be
unfair to You or to Your interest.
If and when We decide to process Your personal data on
the basis of legitimate interest, We will inform You of such, what said
legitimate interest is and provide a process whereby You will be able to raise
any questions and/or objections which You way have in relation to such
processing. It is important to note that The Company is not obliged to stop
processing if the grounds for processing override Your right to object.
PROCESSING ON THE BASIS OF YOUR CONSENT
Consent is not the only ground we may be permitted or
obliged to rely on to process Your personal data. We will only process personal
data on the basis of Your consent where we cannot or otherwise choose not to
rely on any ulterior legal ground (such as compliance with a legal obligation
or legitimate interest). Where we process Your personal data on the basis of
Your consent, you shall have the right to withdraw your consent at any time and
in the same manner as it had been previously provided by Yourself. In the case
that You exercise Your right to withdraw consent, we would then determine
whether we are able (or obliged) to process Your personal data on the basis of
any other legal ground other than consent. If this is the case We will notify
You accordingly. Any such withdrawal of Your consent will not invalidate any
processing operations carried out prior to You having withdrawn Your consent.
DATA RETENTION POLICY
Any and all personal data The Company will keep will
be protected in the best way possible and will only be used for purposes which
are compatible with the applicable Data Protection Laws as well as any other
applicable laws. The Company will retain Your Personal Data only for as long as
is necessary (taking into consideration the purpose for which it was originally
obtained). The criteria We use to determine what is ‘necessary’ depends on the
particular Personal Data in question and the specific relationship We have with
You (including its duration).
Generally, Our normal practice is to determine whether
there is/are any specific EU and/or Maltese law(s) (for example tax or
corporate laws) permitting or even obliging Us to keep certain Personal Data
for a certain period of time (in which case We will keep the Personal Data for
the maximum period indicated by any such law). For example, any data that can
be deemed to be ‘accounting records’ must be kept for ten (10) years.
We would also have to determine whether there are any
laws and/or contractual provisions that may be invoked against Us by You and/or
third parties and if so, what the prescriptive periods for such actions are
(this is usually five (5) years). In the latter case, We will keep any relevant
Personal Data that We may need to defend Ourselves against any claim(s),
challenge(s) or other such action(s) by You and/or third parties for such time
as is necessary.
Where Your Personal Data is no longer required by Us,
We will either securely delete or anonymise the Personal Data in question.
Failure to provide Your Personal Data may prevent The
Company from meeting its legal and regulatory obligations, fulfilling its
contractual obligations and rendering and/or performing the necessary services
needed to satisfactorily manage and maintain Your account. Therefore, failure
to provide the necessary personal data may lead to The Company being unable to
provide its products and/or services.
PERSONAL DATA WHICH WE COLLECT, PURPOSE OF THE
PROCESSING & LEGAL BASIS OF THE PROCESSING
The following table outlines the categories of
personal data which We process, the purpose for which We process such data as
well as the corresponding legal basis used for such processing. It is pertinent
to know that the same categories of personal data may be processed for
different purposes and therefore on the basis of a various legal grounds
simultaneously depending on the purpose of processing.
PERSONAL
DATA |
PURPOSE
OF THE
PROCESSING |
LEGAL
BASIS USED FOR
PROCESSING[FF1] |
Contact data (Ex: Name, Surname, mobile number, email address) Registration data (Ex: Username, password) |
To set up an account on Our system and register you,
the ticket seller, as a new user. To enforce our terms and conditions. |
Contractual Necessity Legitimate Interest (ensuring we maintain an
accurate record on Our system) |
Contact data
Registration data |
To manage our ongoing relationship with you. To give you access to the Mobile Application and, or
Website. |
Contractual Necessity |
Contact data
|
To fulfil Our contractual obligations with you such
as processing any purchase you make through our Website https://thedanceisland.com/.
To provide you, the Customer, with a copy of tickets
and receipts for any purchases made. |
Contractual Necessity
Legal Obligation |
Contact data Registration data |
To subscribe to a newsletter, campaigns and/or to be
added to a mailing list. To present you with offer and promotions. |
Your consent |
Data required for marketing purposes (Ex: Name, Surname, mobile number, email address,
proof of opt-in consent (where required), proof of objections to marketing,
website data and online identifiers (such as IP address, and other
information generated by Your browser)) |
To provide You with marketing material that You have
requested from Us or that we are otherwise authorised to send You. To personalise Your customer experience. |
Your consent (where required) |
The Company may also collect personal data from
publicly available sources such as web searches, company registers and
broadcast media provided it is reasonable to do so and such conduct is not
detrimental to Your rights and freedoms.
MARKETING AND EVENTS
Subject to any preferences You may have chosen (where
applicable), personal information will be used to deliver marketing and event
communications to You across various platforms. We will do this during
the period of Your relationship with Us and, unless specifically instructed
otherwise by you, for a reasonable period of time after the relationship has
ended in order to inform You about products, services, promotions and special
offers which We think may be of interest to you.
Whenever an email or SMS in
relation to marketing is sent, it will include instructions on how to opt out
of receiving these marketing communications in the future. You can also manage
Your information and update Your marketing preferences through the “My Account”
tab when You login to Your account. Please allow up to 48 hours for any changes
You make to Your marketing preferences to be fully processed. Please remember
that even if You opt out of receiving marketing emails, We may still send You
important Service information related to Your accounts and relationship with Us.
We will, from time to time, send You marketing material which may be of
particular interest to You based upon Your interests. These marketing messages
will provide You with information about the products, services, active promotions
or offers available to You by any company within the Group and information
about products and services provided by Our selected partners and third
parties.
Except where We use Your personal data for marketing
purposes on the basis of Your prior written consent and subject to any opt out
preferences You notify to Us in respect of electronic direct marketing
communications, We process personal data for marketing purposes as necessary
for the purpose of Our legitimate interests in promoting Our products and
services.
PROFILING
We do not carry out any profiling or other automated decision-making
while processing Your Personal Data.
COOKIES
We do not use cookies on our website https://tditicketing.com/ or on our Mobile Application.
When
You visit https://thedanceisland.com/, We may
collect certain categories of Personal Data automatically through the use of
cookies and similar technologies that may be used by third party code or
libraries. [FF2] You
have the option to either accept or refuse these cookies and know when a cookie
is being sent to your device. If you choose to refuse our cookies, you may not
be able to use some portions of this Service.
What are Cookies?
A cookie is a small text file
(typically numbers and letters) that is downloaded onto ‘terminal equipment’
(e.g. your computer or smartphone) when you (or someone else) access a website
using that device. Cookies are then sent back to originating website on each
subsequent visit – and they are useful because they allow a website to
recognize a user’s device and store some information about your preferences or
past actions.
Some cookies are needed for
the sole purpose of carrying out the transmission of a communication over an
electronic communications network – others may be necessary for the provision
of a service over the internet, in which case they have to be used. Other
cookies may be desirable to improve your experience, in which case we will ask
you for your consent to use them.
How do you change your cookie
settings?
To find out more about
cookies, including how to see what cookies have been set and how to manage and
delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
OTHER PURPOSES
We may be required to use and retain personal
information for; loss prevention; and to protect Our rights, privacy, safety,
or property, or those of other persons in accordance with Our legitimate
interests.
AUTHORISED DISCLOSURES OF PERSONAL DATA TO THIRD
PARTIES
Without prejudice to anything else contained in this
Privacy Policy, personal data relating to You may be shared with authorised
third parties located in or outside of the EU/EEA where such disclosures are
permitted or required pursuant to Data Protection Laws and/or any other
applicable legislation. These authorised third parties may include but are not
limited to entities within the Dance Island Group, payment service providers, other
third parties and organisations such as law enforcement agencies, collaborating
accounting firms, digital marketing providers, regulators, relevant
authorities, credit reference agencies, fraud prevention and AML agencies, identity
verification agencies and sports governing bodies. We may also share such
personal data with organisations who have introduced You to Us, third parties
which You have asked Us or permitted Us to share Your data with or any other
third party which We must necessarily share Your personal data with so as to be
able to provide the products and/or services which You have requested. The
personal data shared will depend on the product/s and or service/s You choose
to use. We may also share Your personal data within the Dance Island Group for
the purposes of developing and improving Our products/services and for
developing additional services which will serve You and improve Your customer
experience.
When any personal data has to be transferred outside
of the EEA – European Economic Area, We ensure that all the necessary and
appropriate safeguards are in place. We may also disclose personal information
to other companies within associated or subsidiary companies and to business
partners, or successors in title to Our business. The manner in which data
transfer outside the EEA is handled is detailed below. Your Personal Data will
never be shared with third parties for their marketing purposes (unless You
give Your consent thereto).
We use a select number of trusted external service
providers for certain technical support, software support services, software
development services, Mobile Application backend management, server hosting, processing
and/or storage offerings (e.g., IT and related services). These service
providers are carefully selected and meet high data protection and security
standards. We only share information with them that is required for the
services offered and we contractually bind them to keep any information we
share with them as confidential and to process Personal Data only according to
our instructions. In addition to services providers, other categories of third
parties may include:
– Vendors/public institutions. To the extent
that this is necessary in order to make use of certain services requiring
special expertise (such as legal, accounting or auditing services) we may share
your personal data with vendors of such services or public institutions that
offer them (e.g. courts). The legal basis of this data processing is Art.
6(1)(f) GDPR.
– Disclosures to Protect Us or Others. We may access, preserve, and disclose any
information we store associated with you to external parties if we, in good
faith, believe doing so is required or appropriate to: comply with law
enforcement or national security requests and legal process, such as a court
order or subpoena; to protect your, our or others’ rights, property, or safety;
enforce our policies or contracts; collect amounts owed to us; or to assist
with an investigation or prosecution of suspected or actual illegal activity;
depending on the concrete issue, the legal basis for such processing may be
Art. 6(1)(b), (c) or (f) GDPR.
– Disclosure in the Event of Merger, Sale, or Other
Asset Transfers. If we are involved
in a merger, acquisition, financing due diligence, reorganization, bankruptcy,
receivership, purchase or sale of assets, or transition of service to another
provider, then your information may be sold or transferred as part of such a
transaction, as permitted by law and/or contract. The legal basis for such
processing would be Art. 6(1)(f) GDPR as such processes are in the legitimate
interest of Dance Island.
LINKS TO THIRD PARTY SITES
Links that We provide to third-party websites are
clearly marked and We are not in any way whatsoever responsible for (nor can We
be deemed to endorse in any way) the content of such websites (including any
applicable privacy policies or data processing operations of any kind). We
suggest that You should read the privacy policies of any such third-party
websites.
TRANSFER OF DATA OUTSIDE OF THE EEA
Your personal data will only be transferred outside of
the EEA or any other non-EEA country which has been deemed by the European
Commission to offer an adequate level of protection (also referred to as “white-listed
countries” – listed here https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en#:~:text=The%20European%20Commission%20has%20so,commercial%20organisations%20participating%20in%20the ) in
the following circumstances: When You have expressly consented Us to do so;
when it is necessary to constitute or execute a contract entered between You
and the Company; or to be compliant and in line with any and all legal
obligations or duties.
DATA SUBJECT RIGHTS
The Company undertakes to assist You in the best way
possible should You choose to exercise any of Your rights with respect to Your
personal data. In certain cases We might need to verify Your identity prior to
acceding to Your request to exercise any relevant right.
Right of Access
You have a right to ask Us whether We are processing
any personal data which concerns You and if this is the case, You shall have
the right to access that personal data as well as the following information:
– What Personal Data We have
– Why We process them
– Who We disclose them to
– How long We intend on keeping them for (where
possible)
– Whether We transfer them abroad and the safeguards
We take to protect them
– What Your rights are
– How You can make a complaint
– Where We got Your Personal Data from and whether We
have carried out any automated decision-making (including profiling) as well as
related information
Right to Rectification
You have a right to ask us to have any inaccurate or
incomplete Personal Data relating to You rectified and/or completed.
Right of Erasure (the “right to be forgotten”)
You have the right to ask Us to delete Your Personal
Data and We shall comply without undue delay but only where:
– The Personal Data are no longer necessary for the
purposes for which they were collected; or
– You have withdrawn Your consent (in those instances
where We process on the basis of Your consent) and We have no other legal
ground to process Your Personal Data; or
– You shall have successfully exercised Your right to
object (as explained below); or
– Your Personal Data shall have been processed
unlawfully; or
– There exists a legal obligation to which We are
subject; or
– Special circumstances exist in connection with
certain children’s rights.
In any case, We shall not be legally bound to comply
with Your erasure request if the processing of Your Personal Data is necessary
to comply with a legal obligation imposed on Us.
Right to Restriction of Processing
You have the right to ask Us to restrict the
processing of Your personal data. However, You are only able to exercise this
right where:
- The
accuracy of Your Personal Data is contested (see the right to data
rectification above), for a period enabling Us to verify the accuracy of
the Personal Data; or
- The
processing is unlawful and You oppose the erasure of Your Personal Data;
or
- We
no longer need the Personal Data for the purposes for which they were
collected but You need the Personal Data for the establishment, exercise
or defence of legal claims; or
- You
exercised Your right to object and verification of Our legitimate grounds
to override Your objection is pending.
Should You successfully exercise this right, We would
only be in a position to process Your personal data:
- Where
We have Your consent; or
- For
the establishment, exercise or defence of legal claims; or
- For
the protection of the rights of another natural or legal person; or
- For
reasons of important public interest.
Right to Data Portability
You have the right to ask Us to provide You with Your
personal data which You would have previously provided to Us. We will provide
You such data in a structured, commonly used, machine readable format, or
(where technically feasible) We may have the data sent directly to another Data
Controller, provided this does not adversely affect the rights and freedoms of
others. You may only exercise this right where:
- The
processing is based on Your consent or on the performance of a contract
with You; and
- The
processing is carried out by automated means.
Right to Withdraw Consent
For detailed information on this right, refer to
“PROCESSING ON THE BASIS OF CONSENT” section, above.
Right to Object to Processing
In certain instances, You have the right to object to
the processing of Your personal data. Where we are only processing Your
personal data on the basis of one of the following purposes:
- The
processing is necessary for the performance of a task carried out in the
public interest; or
- When
processing is necessary for the purposes of the legitimate interests pursued
by Us or by a third party,
the processing shall only cease where the Data
Controller has not provided compelling and legitimate grounds which outweigh
the objections raised by You in such a request and which require the processing
to continue.
Where Your data is being processed for direct
marketing purposes, You have the right to object to the processing of Your
personal data at any time.
In all other instances apart from those listed above,
this general right to object shall not subsist.
Right to Lodge a Complaint
As a Data subject You may at any time lodge a
complaint with any relevant Data Protection Supervisory Authority should You
feel that any of Your rights have been impinged by the Company. The Competent
Supervisory Authority in Malta is the Office of the Information and Data
Protection Commissioner (‘IDPC’).
Notwithstanding this right, We kindly ask You to
please attempt to resolve any issues You may have with Us prior lodging a
complaint with the IDPC.
It is important to note that notwithstanding such
rights, The Company may still refuse such request if it can reasonably justify
such decision. Such refusal does not prohibit You from lodging a complaint with
the relevant data protection authority.
CONTACT INFORMATION
If You have any questions or comments about privacy or
should You wish to exercise any of Your individual rights, please contact Us
at: hello@danceisland.com[FF3] .
[FF1]Please
confirm the content in the first two columns. Consult with the developer if
need be. Let me know if you have any questions.
[FF2]After running a search on a free publicly
available source (see https://www.cookieserve.com/) it seems that https://thedanceisland.com/ does in fact
make use of cookies. However you will need to have this confirmed by someone
who is technically qualified.
The information on the cookies used needs to be
included in the below table. Also, technically you need to obtain consent for
the use of cookies which are not necessary for the funcrtioning of the website
(for ex. Advertising coookies). Consent is usually obtained by clicking “I
Accept” on a pop up on the website. I am sure you have seen these before.
[FF3]Please
confirm this is the correct email address.