Privacy Policy

FEVO Global Ltd is a registered controller with the Information Commissioners’ Office in the UK. Our registration number is ZB577905.

Our Data Protection Team can be contacted by:

emailing support@fevo.com. Please make sure that you include Data Protection in the subject line of your email to us; or

writing to:
The Data Protection Team
5 New Street Square
London
EC4A 3TW

This Privacy Policy describes how FEVO Global Ltd (“FEVO”, “we”, "our” or “us”) collects, uses, and discloses your personal data as a controller when:

(1) you interact and use www.fevo.com, www.offer.fevo.com, www.myfevo.com, and any other digital platform where this Privacy Policy appears (the “Sites”);

(2) you interact and use our services, features, content, or applications (collectively with the Sites, the “Services”);

(3) you communicate with us in any way; and

(4) we interact with certain third-party providers and organizations (“Third Parties”).

Please note, this Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications that you access through the Services, including websites of third parties offering goods, services, events, or other offerings utilising the FEVO infrastructure (“Offer Provider”). The Offer Providers are controllers of your personal data and FEVO processes that personal data on the instructions of the Offer Providers as a processor.

While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services you access.

ACKNOWLEDGMENT

BY ACCESSING AND/OR USING OUR SERVICES, AND/OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

WHAT INFORMATION DOES FEVO COLLECT?

The information we gather enables us to (amongst other things) personalise, improve, and operate the Services. In connection with certain aspects of the Services, we may request, collect, use and/or display to you some of your information, including:

ACCOUNT AND PURCHASE INFORMATION

When you create an account for our Services, including third-party websites or applications, such as Offer Provider websites or applications, you will provide information such as your name, email address, phone number, address, payment information, and/or password. We may also ask for information relevant to the offer, event, or prizes that the Offer Provider may provide. Please note, when you provide us with your email address and/or telephone number, we will be creating an account on your behalf to identify and catalogue your purchases through FEVO. However, as stated above, where this is provided in connection with an Offer Provider website or application, we will process this on the instructions of the Offer Provider as a processor.

YOUR COMMUNICATIONS WITH US

We collect information from you such as email address, phone number, or mailing address when you request information about our Services, register for our marketing communications or loyalty program, request customer or technical support or otherwise communicate with us.

ANALYTICAL DATA

We may process analytical data about your use of our Sites ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is Google Analytics and HEAP. This usage data may be processed for the purposes of analysing the use of the Sites and Services.

SURVEYS

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information.

SOCIAL MEDIA CONTENT

We may offer forums, blogs, or social media pages. Any content you provide on these channels will be visible to the public.

SWEEPSTAKES OR CONTESTS

We may run sweepstakes and contests. Contact information you provide, may be used to contact you about future promotional and marketing purposes, if permitted by law. In line with local law, we may be required to publicly share the information of winners with Third Parties.

USER CONTENT

Some features of the Services may allow you to provide content to the Services. This includes content you provide on your profile, and information about what events you have or will attend. We may disclose such content to Third Parties in a manner that does not reveal your identity, where appropriate.

LOCATION INFORMATION

Some of our Services may include features based on your actual location and may report your current location (“Location-Based Services”). To the extent you use any Location-Based Services, we will collect and store information about your location at the time you use those Location-Based Services.

This information can come from a variety of sources you use to access the Services; for example, a mobile phone may report its GPS location or IP address at the time Location-Based Services are used.

You can opt out of Located-Based Services by changing the settings directly on your device.

You can opt in to Location-Based Services through the Cookie Notice on our website.

You can find more information about how Cookies are used in our Cookie Policy (https://www.fevo.co.uk/cookie-policy).

FINANCIAL INFORMATION

If you make purchases through the Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our Third-Party payment processing company (the “Payment Processor") and use and storage of that information is governed by local laws and the Payment Processor's applicable terms of service and privacy policy. We currently use Stripe (www.stripe.com) and Checkout (www.checkout.com) as our Payment Processors. In order to facilitate your order transactions, we collect and store your billing postcode, credit card type and the last four digits of your credit card number, but no other financial information.

SHIPPING INFORMATION

We may collect your shipping information in connection with certain purchases through the Services. We may pass this information to our Payment Processor, Offer Providers, partners, and other Third Parties for purposes of customer service, fulfilment, shipping and returns. The use of your information by such parties is subject to their respective privacy policies and terms where applicable.

INFORMATION FROM OTHER SOURCES

If you access our Services through a Third-Party website or application, such as an Offer Provider, app store, a Third-Party login service, or a social networking site (such as Facebook), we may collect information about you from that Third Party. If you do not want us to receive your personal data from Third-Party sources, please communicate your preferences directly with the relevant Third-Party sources.

Information we collect through these services may include your name, user identification number, username, location, gender, birth date, email, profile picture, and contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

USE OF ANONYMOUS & AGGREGATE INFORMATION

We collect statistical information about how both unregistered and registered users use the Services. Some of this information is derived from your personal data. This statistical information is not identifiable to you. We do not attempt to re-identify it except to ensure our anonymization processes are in compliance with applicable data protection laws.

HOW WILL MY INFORMATION BE USED?

We use your personal data for a variety of business purposes, including to:

Fulfil our contract with you and provide you with our Services, such as:

Customer service-related activities including, managing your information and accounts
Providing access to certain areas, functionalities, and features of our Services
To process your online purchase and deliver the product to you
Communicating with you about your account, activities on our Services, comments and complaints, and policy changes
Undertaking activities to verify or maintain the quality or safety of a Service or device
Processing your financial information and other payment methods for products or Services purchased
Allowing you to participate in sweepstakes, prize draws and contests
Sharing personal data with Third Parties as detailed below
Enforcing our terms and policies

If you fail to provide the personal data required for us to fulfill our obligations under our contract with you, we may be unable to provide you with our Services.

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With your consent:

Providing advertising, analytics, and marketing Services
Furnishing you with (tailored) materials/information about offers, promotions, products, and Services that may be of interest to you, including new content or Services and to send you surveys
Sharing personal data with Third Parties as detailed below
Other purposes you consent to, are notified of, and are disclosed when you provide personal data

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time (i.e., opt out). Note, however, that your withdrawal of consent shall not affect the lawfulness of any processing we carried out, based on consent, before its withdrawal.

Providing, analysing, and improving our Services, and managing our business, pursuant to our legitimate interest, such as:

Auditing relating to interactions, transactions, and other compliance activities to make sure that our e-commerce platform is managed in line with FEVO’s business processes for ISO27001, business continuity arrangements and ensuring quality control of our platform
Sharing personal data with Third Parties, including for the purposes identified below:
- Improving, upgrading, or enhancing our Services or devices such as ‘point of sale’ or those of our Providers including by personalizing features, content, and recommendations
- Furnishing you with (tailored) materials/information about offers, promotions, products, and Services that may be of interest to you, including new content or Services and to send you surveys where we are permitted to do so other than in reliance on your opt-in consent
- Developing new products and Services
- Debugging to identify and repair errors that impair existing intended functionality

In connection with a potential asset or stock acquisition, or the outsourcing or insourcing of services, providing reasonable diligence material to a Third Party, or meeting any disclosure obligations as required by law
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Our legitimate interests are commercial in nature and include advertising, marketing, and promoting our products and Services, and our business. The legitimate interests of our partners are to sell tickets, merchandise and other items related to events that they stage.

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You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.

Complying with our legal obligations, including:

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Auditing relating to interactions, transactions, and other compliance activities to make sure that our e-commerce platform is managed in line with FEVO’s business processes for ISO27001, business continuity arrangements and ensuring quality control of our platform
Sharing or disclosing your personal information if we believe it is reasonably necessary to comply with a law, regulation, legal process, or governmental request
Verifying your identity and preventing fraud

If you fail to provide the personal data required for us to fulfil our legal obligations, we may be unable to provide you with our Services.

PROCESS INFORMATION ON BEHALF OF OUR OFFER PROVIDERS AS A PROCESSOR

Our Offer Providers may choose to use our Services to process certain data of their own, which may contain personal data. The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our Offer Providers and their privacy policies.

If you have any questions or concerns about how such personal data is handled or would like to exercise your rights, you should contact the person or entity who has contracted with us to use the Service to process this personal data.

NOTICE REGARDING THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the information provided by you may be viewed and used by Third Parties for any number of purposes and you should review these companies’ privacy policies in order to understand how they may use your information.

In addition, social media buttons such as Facebook (see below), ‘X’, Instagram, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini programmes) may be used through our Services. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

For the Facebook social plugins (e.g., the Like button) please note that Meta Ireland is a joint controller of the joint processing and further information (including, in relation to the exercise of your rights) can be found in Meta Ireland's Privacy Policy at https://www.facebook.com/about/privacy. We and Meta Ireland have entered into a Controller Addendum (accessible here) to determine the respective responsibilities for compliance with our obligations under the GDPR with regard to the joint processing (as specified in the applicable product terms). We and Meta Ireland have agreed that we are responsible for providing data subjects, as a minimum, with the information included in this section and Meta Ireland is responsible for enabling data subjects' rights with regard to the personal data stored by Meta Ireland after the joint processing.

We may use Third-Party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal data for various purposes including to provide analytics services and content that is more relevant to you.

For more information in relation to third party websites, social media platforms and software

Development kits please read our Cookie Policy (https://www.fevo.co.uk/cookie-policy).

HOW, AND WITH WHOM, IS YOUR INFORMATION SHARED?

Certain of the Services are designed to help you share information with others. As a result, some of the personal data generated through the Services is shared publicly or with Third Parties.

SERVICE PROVIDERS

We may share any information we collect about you with our Third-Party service providers. The categories of service providers to whom we entrust your information include IT and related services; payment processors; customer service providers; and vendors to support the provision of the Services.

BUSINESS PARTNERS

We share your data with our business partners with whom we jointly offer products or services, including Third-Party websites and applications, such as Offer Providers. In such cases, our business partner’s name will appear along with ours.

AFFILIATES

We share your information with our affiliated companies.‍

ADVERTISING PARTNERS

We may allow Third-Party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day).

We may also combine and share such information and other information (such as past purchase history) with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third-Party websites within their networks. This practice is commonly referred to as ‘interest-based advertising’ or ‘online behavioural advertising’. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you.

If you prefer not to share your information with Third-Party advertising partners, please ensure that you check your preferences.

More information can be found in our Cookie Policy (https://www.fevo.co.uk/cookie-policy).

OFFER PROVIDERS (WHERE WE ACT AS A PROCESSOR)

Offer Providers may choose to use our Services to process certain data of their own, which may contain personal data. Some of the data that we process through our Services is processed by us on behalf of the Offer Providers. In these circumstances, they will be the controller of your personal data, and their privacy policies will be applicable where we process personal data on their behalf.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity who has contracted with us to use the Service to process this data. They can be identified by checking who the event organiser is for the event you are attending.

DISCLOSURES TO PROTECT US OR OTHERS

We may access, preserve, and disclose any information we store associated with you to external parties if we, are required to: comply with law enforcement or national security requests and legal processes such as a court order; protect your, our or others’ rights, property, or safety; assist us in complying with our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

DISCLOSURE IN THE EVENT OF MERGER, SALE, OR OTHER ASSET TRANSFERS

If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal data may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

Personal data we collect via this website may be transferred and processed, outside of the UK, EU, or EEA. We routinely share personal data with our parent company FEVO Inc., who provides us with services and such transfers are made in reliance on intra-group data transfer agreements incorporating Standard Contractual Clauses (as amended for transfers from the UK).

Where we enter processing arrangements with companies outside of the UK, EU, or EEA which may have data protection laws that are different from the laws where you live, we will take steps in line with applicable data protection laws to protect your personal data. In particular, such transfers will be made in reliance on appropriate data transfer agreements such as, Standard Contractual Clauses or similar, Binding Corporate Rules, the EU-US Data Privacy Framework and UK Extension thereof, or otherwise in reliance on a derogation for the transfer (e.g., where the transfer is necessary for the defence of legal claims).

Please contact us if you would like further details of the safeguards implemented including, a copy of the data transfer agreements.

WHAT ARE MY CHOICES?

You have certain choices about your personal data.

You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

ACCOUNT DEACTIVATION

Should you ever decide to deactivate your account, you may do so by emailing support@fevo.com. If you deactivate your account, any association between your account and information we store will no longer be accessible through your account. However, given the nature of sharing on the Services, any public activity on your account prior to deactivation will remain stored on our servers and will remain accessible to the public in accordance with applicable law.

HOW LONG IS INFORMATION RETAINED?

We store the personal data we process as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

For further information please contact us.

PRIVACY RIGHTS

Where FEVO is the controller of your personal data and subject to certain limitations, you have the right to:

(a) request access to your personal data and to receive certain other information about our processing activities

(b) request the correction of your personal data if it is inaccurate or incomplete

(c) request the erasure of your personal data. In some circumstances personal data is not able to be erased as FEVO has a legal obligation to retain your personal data. You will be advised if this is the case.

(d) request the restriction of the processing of your personal data. When processing is restricted, we can still store your personal data, but may not use it further, unless we have your consent or need to process your personal data in connection with a legal claim or important public interest.

(e) object to the processing of your personal data

(f) data portability (including, to have your personal data transferred to a Third Party)

(h) withdraw consent to the processing of your personal data, although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful

To exercise these rights, you can contact us using the designated email provided below. If you have unresolved concerns, you have the right to lodge a complaint to the Information Commissioner’s Office about the way in which your personal data is being used (www.ico.org.uk).

Where FEVO is the processor of your personal data we will assist the relevant controller in responding to your privacy rights’ request.

To exercise data subject rights against Meta Ireland, further information can be found in Meta Ireland's Privacy Policy at https://www.facebook.com/about/privacy.

CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal data from children. If you learn that your child has provided us with personal data without your consent, you may contact us as set forth below. If we learn that we have collected any personal data in violation of applicable law, we will promptly take steps to delete such data and terminate the child’s account.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email.

CONTACT US

If you have any questions or concerns regarding the processing of your personal data, please send us a detailed message to support@fevo.com. We will make every effort to resolve your concerns.

5 New Street Square
London
EC4A 3TW

ACCESSIBILITY

This Privacy Policy uses industry-standard technologies and was developed to align with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

12^th March 2024