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
- 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
- When you access or use our Digital Services (mobile
- 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
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
- 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:
- verifying your identity for authentication and security purposes;
- helping us to ensure our customers are genuine and to prevent fraud;
- to help us to return lost property to its rightful owner; and
- managing access to specific areas of our Venues.
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:
- preventing and detecting crime and to help keep people who visit and work at our Venues safe and secure;
- recording and investigating health and safety and other incidents which have happened or may have happened at our Venues;
- counting the numbers of people who visit our Venues and to analyze flows of people around the Venues for safety and commercial purposes using software which analyzes CCTV camera images; and
- creating aggregate data.
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.
- ensuring the security of our websites, mobile applications and other technology systems; and
- analyzing the use of our Services, including navigation patterns, clicks, etc., to help us understand and make improvements to the Services.
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
- for “essential” or “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain a basket when they are shopping at an online store);
- for “analytics” purposes, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it, what website they visited prior to visiting our website, and use this information to understand user behaviors and improve the design and functionality of the website); and
- for “retargeting” or similar advertising or commercial purposes, such as:
- for social media integration e.g., via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter; and
- to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising;
- to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website but have not purchased).
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:
- verifying your identity for authentication and security purposes (in which case we may process Government ID Data to complete verification); and
- helping us to ensure our customers are genuine and to prevent fraud.
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:
- Counting ad impressions to
unique visitors, verifying positioning and quality of ad impressions, and
auditing compliance (this could include compiling aggregate statistics
regarding the use of the Services, and for other research and market analysis);
- Helping to ensure security and
integrity, such as by securing our Events, Venues, and Services and by
- Debugging, identifying and
repairing errors that impair existing intended functionality;
- Short-term, transient use,
including, but not limited to, non-personalized advertising shown as part of
your current interaction with us (without us disclosing your Personal Data to a
third party or using it to build a profile or change your experience beyond
your current interaction with us);
- Performing services on behalf
of our business, including maintaining or servicing accounts, providing
customer service, processing or fulfilling orders and transactions, verifying
customer information, processing payments, providing financing, providing
analytic services, providing storage, or providing similar services on behalf
of the business (this could include supporting compliance with the law, and for
other purposes in the public interest as well as supporting events you attend;
fulfilling our contractual obligations to you; maintaining the quality and
stability of and generally improving our Services);
- Providing advertising and
marketing services (except for cross-context behavioral advertising) to you,
including by personalizing the Services in connection with marketing and
advertising (including behavioral advertising);
- Undertaking internal research
for technological development and demonstration; and
- Undertaking activities to
verify or maintain the quality or safety of a service or device that we own,
manufactured, was manufactured for us, or is controlled by us; and to improve,
upgrade, or enhance that service or device (such as an RFID entry/access
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.
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.
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
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:
- Marketing communications,
- Creating marketing profiles,
- In connection with online advertising, including targeted advertising, and
- Data sales.
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:
- When you make a purchase or other transaction through our Service;
- When you attend our Event Venues;
- When you access or use our Digital Services;
- Cookies and other tracking technologies;
- When you enter a contest or other promotion;
- When you contact us or submit information to us; and
- Feedback and Surveys
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.
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.
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.