1.1 Resident Advisor Limited, a company registered in England with company number 05871093, whose registered office is Norway Wharf, 26 Hertford Road, London, N1 5QT (“RA”, “us”, “we”, “our”) is the ‘controller’ of your personal information for the purposes of all applicable data protection laws, including the General Data Protection Regulation 2016/679 and the UK GDPR (together, the “GDPR”).
1.2.1 an individual simply browsing the Online Services;
1.2.2 an electronic music “Fan” who has registered an account with us;
1.2.3 a “Promoter” of electronic music and events who has registered a registered Promoter account with us;
1.2.4 an “Artist” who has a registered artist profile with us; and
1.2.5 a “Label” who has a registered label profile with us,
together, “Users” of the Online Services.
1.3 The Policy explains how we collect, use and disclose your personal information when you use the Online Services including:
1.3.1 “Sale Service” through which Promoters, Artists and Labels can sell tickets and other goods to other Users;
1.3.2 “Resale Service” through which Users can sell on tickets to events that they have purchased but no longer wish to use;
1.3.3 “RA Guide” through which Users can discover clubs, DJs and electronic music events personalised to their taste and location;
1.3.4 “Ticket Scanner” used by Promoters to manage attendance of events, including with RA guestlist management tools;
1.3.5 RA reporting service to better understand ticket sales performance and purchasing trends;
1.3.6 RA advertising partnership services to build, manage and optimise campaigns delivered to Users;
1.3.7 Content contribution through which Users can contribute content for the RA magazine to be published on the Online Services; and
1.3.8 The RA “Inbox” used by Users to communicate with one another on the Online Services.
1.4 The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
1.8 If we change our Policy and/or personal data processing procedures, we will post those changes on our Website to keep you aware of what personal data we collect, how we use it and under what circumstances we may disclose it. We encourage you to review this Policy regularly.
1.9 In addition to this Policy, each service offered by us or our group companies may have additional privacy provisions that are specific to the particular service. These supplemental disclosures are made adjacent to the particular service at the time your personal information is collected.
2. PERSONAL INFORMATION WE MAY COLLECT ABOUT YOU
2.1 We collect and process the following personal information which may include your personal data.
When you register as a Fan using our Online Services
When you register to use our Online Services, we will require some personal information about you. This may include:
first name and last name;
date of Birth;
location (city / region)
any personal information you choose to include in your ‘bio’; and
your preferences with regards to receiving our newsletter and other similar communications.
The Online Services are public. However, we give you choices over the extent to which your profile is available to view by other Users, and whether:
your real name displays on your profile or on listings; and
whether your friends with RA User profiles are able to invite you to upcoming events through the Online Services.
We therefore also process your preferences in relation to the above. If you choose to make your profile viewable by other Users they will be able to search for and view your profile and the information you choose to include on it, and other Users will be able to search for your RA username in order to send you messages through our ‘inbox’ functionality.
Where you register as an Artist using our Online Services
When you register to use our Online Services as an Artist, we will require some personal information about you in addition to the information set out in the section relating to User registration above (you need an RA User profile in order to set up an artist or label profile). This may include:
first and last name;
home country and area;
area of residence (country and area)
record label(s) you’ve released music on;
any information you choose to include in your biography and discography;
links to your official website or social media channels (Twitter, Discogs, Facebook, Soundcloud, Bandcamp, Instagram);
upcoming and past events; and
logo and/or profile picture.
Once you register as an Artist, your Artist profile will be publicly viewable and searchable on the Online Services, and other Users will be able to search for your RA username in order to send you messages through our ‘inbox’ functionality. Where a User views your profile they will be able to view the information listed above together with certain statistics about you, including the number of Users following you on the Online Services, the clubs and regions in which you’ve played the most, and the first event you performed at which is listed on the Online Services.
Where you register as a Label using our Online Services
When you register to use our Online Services as a Label, we will require some personal information about you in addition to the information set out in the section relating to User registration above (you need an RA User profile in order to set up a label profile). This may include:
country and area;
artists on the label;
links to website and social media (Discogs, Facebook, Twitter and Soundcloud);
any information you choose to include in the description and updates sections;
upcoming and past events; and
Once you register as a Label, your Label profile will be publicly viewable and searchable on the Online Services, and other users will be able to search for your RA username in order to send you messages through our ‘inbox’ functionality. Where a User views your profile they will be able to view the information listed above together with certain information about your Label, including the number of Users following your Label on the Online Services, your Label’s location (country) and links to your Label / social media website.
Where you register as a Promoter using our Online Services
When you register to use our Online Services as a Promoter, we will require some personal information about you in addition to the information set out in the section relating to User registration above (you need an RA User profile in order to set up a Promoter profile). This may include:
address (country and area);
links to website and social media (Facebook, Twitter, Youtube and Instagram);
anything you choose to include in the ‘about’ section;
upcoming and past events; and
Once you register as a Promoter, your Promoter profile will be publicly viewable and searchable on the Online Services, and other users will be able to search for your RA username in order to send you messages through our ‘inbox’ functionality. Where a User views your profile they will be able to view the information listed above together with certain information about you, including the number of Users following your profile on the Online Services, your location (country) and links to your social media / website.
When you make purchases or sign up for tickets
When you make purchases (for example, of merchandise) or sign up for tickets through our Online Services, you will be required to provide us with the following information:
first and last name;
bank account and other payment information; and
We use the third-party payment processors Braintree and Paypal in order to take your payments, and you will provide your payment details directly to them. We do however store redacted versions of this information on our own systems, including in connection with the ‘save card’ feature which lets you save your card for future purchases
We will link your purchases/event registrations to your RA User profile so that we are able to identify which Users have purchased tickets for which events or purchased certain merchandise. We also record the details of which events you have purchased tickets to, whether you have purchased tickets to events from the same Promoter / Artist or Label before, and wider aggregated reports with regards to sales (such as the split of genders purchasing tickets to events, or regional breakdowns of the Users purchasing tickets). This information may be shared with Promoters, Artists and Labels (see ‘How we disclose your information to third parties’ below’ for further information).
When you choose to sync your RA profile with third party platforms
We offer you the choice to sync your RA User profile with your profile on third party platforms, Spotify and Apple Music. Where you choose to do so, we will have access to the personal information on your profile on such platforms (such as username and profile picture), and will be able to personalise the events and music we display to you through the Online Services (including the Website and RA Guide), based on the music, artists and content you have engaged with on the other platform.
When you use our Inbox
When you use our Inbox to send messages to other Users, we will process any information you choose to include in such messages. The personal information you provide in this respect is entirely up to you. Please do not share personal data about third parties or any sensitive personal data about yourself.
When a friend sends you a message through the Inbox, we will process your RA username in order to facilitate the sending of the message to you.
When you use the RA Guide
"RA Guide Data”
The RA Guide is a personalised event and music discovery service available through the RA Guide app. We personalise the events and music displayed to you based on:
the artists you follow through your User account
events you have attended in the past; and
the geolocation of your device.
We also need to process your RA account login information in order to link your user session within the RA Guide app to your RA account.
When you use the Resale Service
As part of the Online Services, and where the Promoter of the relevant event permits it, we offer the Resale Service through which you can sell any event tickets that you have previously purchased but which you no longer want at face value. We may process the following information in order to do so:
first and last name; and
We use the third party payment processors Braintree and Paypal in order to take your payments, you will provide your payment details directly to them. We do however store redacted versions of this information on our own systems, including in connection with the ‘save card’ feature which lets you save your card for future purchases.
When you submit events to the Online Services
If you are involved with the organisation of an event and you submit that event to the Online Services in order to publicise and sell tickets to such event, we will process any information contained within the content you provide relating to such event, and your name / RA username. Other Users may use your name / RA username to send you messages via the RA ‘inbox’.
When you contact us or use our support services
We provide our support services via our Website and by email. The personal information we may process in connection with this may include:
first and last name;
email address with which you have signed up to your Online Services account or which you contact us from;
the element of the Online Services causing an issue for you;
a description and/or screenshots of the issue you are experiencing; and
content files, where relevant.
You are under no obligation to provide us with any details, but if you don’t provide all relevant Information, we may not be able to help.
When you attend an event supported by RA
"Guestlist and Event Data”
Where you attend events supported by the RA Ticket Scanner, the barcode on your ticket will be scanned when you enter the event, and RA will process the data relating to your attendance, namely:
the fact that you attended;
the time you arrived; and/or
whether you were denied entry to the event.
This data will be shared with the relevant Promoter, Artist or Label.
Information collected for the purposes of analytics
We may collect technical personal information about your use of the Online Services through the use of tracking technologies and analytics. This may include:
your Device ID;
your user ID;
your IP address;
your device operating system & version;
your device make and model;
purchase transaction types and spend you have made;
the country of your Device ID;
the time, date and install source of your first download of an App (e.g. from a clicked advertisement);
page visited, button clicks and search terms used on our Online Services;
advertisements viewed and clicked; and
identification of crashes and defects.
We may also use third-party analytics providers to assist with analytics.
Personal information about you collected from third parties
Third Party Log In Information:
When you access the Online Services via a third party such as Apple, we may collect and store personal and non-personal information which is available from your account with such third party provided that you have expressly agreed to the use of the third party’s cookies within our Online Services. The information will include the username and/or ID associated with your account with such third party. We will also receive technical data (namely a digital ‘token’) in order to ensure our Online Services connect to the correct account on the third party platform.
Third Party Guestlist Information
Where a Promoter, Artist or Label uses our guestlist management tools and you have signed up to attend an event run by them, they may import a guestlist generated outside of the Online Services into the Online Services. Whilst we are not responsible for the initial data collection in these circumstances, we will process the information contained in the guestlist which is likely to include your first and last name, email address, address, gender, age, phone number and information relating to the tickets you have purchased / signed up for, in each case in line with the rest of this policy.
Personal information collected in relation to social media channels
If you post or upload any content about our Online Services on social media channels such as Facebook, Instagram or Twitter, this will be under these social media platforms’ respective privacy policies which can be found on their websites.
Where you follow us, interact with our content, or choose to link your social media channels to your account with us, we may be able to see personal data from your social media profile (depending on your social media privacy settings), including:
first and last name (and/or your social media unique username);
email and/or postal address;
IP or MAC address;
gender and/or age;
correspondence with us through those channels; and
general interests and preferences (e.g. Likes, Follows, Shares, Posts).
We do not make use of this personal information other than to respond to your comments or enquiries (including to provide support with your RA User account) to the extent you send them to us through social media channels.
Information used for the purposes of serving advertisements
We may gather personal information about you when you use our Online Services. This may include:
the make, model and operating system of your device;
properties of your device, such as screen size and orientation, audio volume and battery;
the mobile network operator linked to your device;
the apps downloaded;
the country, time zone and locale settings on your device (i.e. country and preferred language);
network connection type and speed;
internet browser used to access the Online Service; and
the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.
Information collected when you sign up to receive direct marketing communications such as our newsletter
If you sign up and consent to receive direct marketing communications such as a newsletter or to enter a competition, you may provide us with contact information which may include:
first and last name;
marketing preferences data.
3. WHY WE COLLECT PERSONAL INFORMATION ABOUT YOU
To provide our Online Services to you
We will use personal information about you for delivering our Online Services to you, including to:
register you for an RA User account and facilitate your logging into your RA User account;
manage User accounts;
operate and administer the Sale Service, Resale Service, the Inbox;
publish your event on our Online Services;
facilitate the syncing of your RA profile with third party platforms such as Spotify and Apple Music;
facilitate and fulfil orders or purchases you make (of event tickets, merchandise or otherwise).
Unless a particular Online Service is specifically addressed below, we process your personal data in this way in order to perform the contract we are about to enter into or have entered into with you, and for our legitimate interests of offering the Online Services to Users. The processing of personal information is necessary for us to deliver the features promised (including the Artist and Promoter features) and for the features to function properly, so that you have the best experience when using our Online Services.
To better understand the use of our Online Services
We process your personal information, Analytics Data and Purchase History in order to:
better understand your use of our Online Services;
identify the most popular music, events, Promoters, Artists and Labels; and
understand how the popularity of music, events, Promoters, Artists and Labels differs according to User characteristics (such as gender or regional location).
We do this on the basis of our legitimate interest in developing a deep understanding of User engagement with our industry so that we are better able to meet popular demand.
To send you email marketing
We may process your contact information, and marketing preferences data for our mailing list in the following way:
Consent-based mailing lists: We may process your personal data to keep you updated with information on news, offers, and updates about us. We rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time. Please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.
‘Soft opt-in’ or B2B mailing lists: In some instances (such as with our existing UK customers, or where we act as an agent on behalf of a Promoter and you are an existing customer of the Promoter) the law may permit us to process your personal data in order to send information to you by email that we think is of interest to you and/or your business on the basis of our legitimate interests, being our legitimate interest to promote our business, or the legitimate interests of the Promoters (where we act as an agent on their behalf) being their legitimate interest to promote their business. If you would like to be removed from that list, please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.
To provide the RA Guide to you
We process the RA Guide Data in order to deliver the RA Guide feature to you, on the basis of the contract we have entered, or are about to enter, with you.
To facilitate guestlist and event management
We process your Guestlist and Event Data and Third Party Guestlist Information in order to:
assist Promoters, Artists and/or Labels in the management and administration of event guestlists and attendees;
whether tickets sold via the Online Services are ultimately used, and
attendance trends for events marketed through the Online Services (such as the times doors were busiest).
We do so on the basis of our legitimate interest in: (a) providing the Promoters, Artists and/or Labels with the service described above; and (b) developing a deep understanding of User engagement with our industry so that we are better able to meet popular demand. We also do this on the basis of your legitimate interest in the events you attend being administered effectively and efficiently.
To fulfil our Anti-Money-Laundering obligations
We may request specific information from you to help us confirm your identity under the Know Your Customer / Anti-Money-Laundering Regulations (“AML Regulations”), to verify your identity prior to paying financial incentives to selected Artists / finalists or those providing commissioned work under the AML Regulations. We will process information about you in this way to comply with our legal obligations.
To help us improve the Online Services and fix any problems
We may process personal information about you (including Analytics Data) so that we can analyse and improve our Online Services. This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other Users have the best experience when using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our Users; (iii) identifying and correcting any bugs in the Online Services and (iv) understanding the effectiveness of our marketing to attract new Users and re-engage our current Users.
To respond to your enquiries and requests for support
If you contact us about our Online Services, the forms you complete or the emails you send may include personal information about you, such as your name as the contact point for an organisation, your email address, the organisation’s address and your enquiry. Similarly, if you contact us via social media channels we may be able to see personal information from your social media account. In each case, we use this personal information to respond to your enquiries.
We process this personal information in accordance with the terms of our contract with you (where we need this personal information to provide our Online Services to you) or to take steps at your request prior to entering into a contract.
We also use this personal information to pursue our legitimate interests in responding to your enquiries and requests for support, and to understand our customers and improve our Online Services.
You are under no obligation to provide us with any details, but if you don’t provide all relevant personal information, we may not be able to help.
To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our Online Services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations. We use a third party provider Ravelin Technology Ltd to provide fraud prevention services some of which involve automated decision making methods which do not involve human involvement to process your personal information.
To acquire new users and engage current users
We may process personal information (including Purchase History, Advertising Data and Analytics Data) to encourage engagement from existing and new Users and to notify them of promotions on offer and to improve the relevancy of our marketing. We process this personal information to pursue our legitimate interests of promoting our Online Services and extending our engagement with Users.
For advertising purposes
We may process Advertising Data to show you advertisements on our Online Services (or third party services) for products or services provided via our Online Services based on your previous purchases with us.
The personal information we collect about you may be used to understand how advertisements placed have performed or how many people have viewed certain advertisements. We aggregate this personal information so that it does not personally identify you or permit you to be treated individually.
This processing is necessary for us to pursue our legitimate interest of providing you with adverts that are relevant and interesting to you.
4. WHAT RIGHTS DO YOU HAVE IN RESPECT OF THE INFORMATION WE PROCESS?
4.1 You have the following rights over the way we process personal information relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
you consented to our processing the personal data, and have withdrawn that consent;
we no longer need to process that personal data for the reason it was collected;
we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of ours or of a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed;
you need the personal data to be deleted in order to comply with legal obligations; or
the personal data is processed in relation to the offer of a service to a child.
Obtain a machine-readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this personal information directly to another IT system provider if you prefer.
Make a complaint to a supervisory authority
If you are unhappy with the way we are processing your personal data, please let us know by contacting us via our support services.
If you do not agree with the way we have processed your personal data or responded to your concerns, an alternative is to submit a complaint to a data protection supervisory authority. In the UK, this is the Information Commissioner’s Office with whom we are registered:
https://ico.org.uk/concerns, or you can submit a complaint to the supervisory authority in your country.
To make a request, please let us know by sending an email to [email protected].
5. How WE DISCLOSE YOUR PERSONAL INFORMATION TO THIRD PARTIES
We will share your personal information with third parties only in the ways that are described in this Policy
We may share your personal information with third parties as specifically approved by you or under the circumstances described below.
Group members, personnel, or subcontractors: We keep your personal information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. However, this is on the basis that they do not make independent use of the personal information, and have agreed to safeguard it.
Promoters, Artists and Labels: Where you enter into a transaction with a Promoter, Artist or Label, such as in order to purchase an event ticket, your personal information may be shared with such Promoter, Artist or Label as part of the order fulfilment or ticketing service. Some examples of this may be but are not limited to:
if you have purchased a ticket to an event, the Promoter, Artist or Label hosting the event may require your name and contact details to add you to a guestlist or contact you if the event is cancelled,
if you have signed up up for a preregistration to be notified of an event before it goes on sale,
if you have signed up for ticket notifications to to join a waitlisting to be notified if new tickets are available.
RA also shares reporting statistics such as your Purchase History with Promoters, Artists or Labels so that they may process it for their own purposes. Prior to receipt of any personal information from RA in this way, RA requires the Promoter, Artist or Label to agree to process your personal information in accordance with the GDPR. We are not responsible for the privacy policies or practices of Promoters, Artists or Labels. Please contact us at [email protected] if you would like to know more about this disclosure of your personal information.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your personal data with the buyer. You will be notified via account message and/or a prominent notice on our Platform of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
Required by law: In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing personal information to others for the purposes of fraud prevention); or to comply with requests from police or other authorities.
Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our users, or others.
Suppliers: We use third-party suppliers (such as IT service providers, professional advisers, payment processors, order/delivery fulfilment providers, fraud prevention providers, analytics and data hosting providers) to help provide a professional service to our customers. These organisations act as data processors and are strictly controlled in how they may/may not use your personal information and we remain responsible for the protection of your personal information.
Messaging using our Inbox and personal information included on your User profile: Please be aware that any personal information that you make available when you send messages using our Inbox, or (depending on your privacy settings) include in your User profile may be disclosed and available to all Users who have access to that portion of our Online Services.
6. INTERNATIONAL TRANSFERS OF INFORMATION
6.1 We store all personal information in our database located in the UK.
6.2 We may transfer your personal data to locations outside of the UK, for example to members of our corporate group or to providers who deliver services to us.
6.3 Where we transfer your personal data outside of the UK, we will have appropriate safeguards in place to protect your personal data where required, an example of which may include standard data protection clauses adopted by a data protection regulator to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about the safeguards we use for these purposes, please let us know by writing to [email protected].
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only keep your personal information for as long as it is reasonably necessary to do so bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain personal information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
8. SECURITY OF YOUR INFORMATION
8.1 We will take all reasonable technical and organisational precautions to prevent the loss, misuse or unauthorised alteration of your personal data.
8.2 Please be aware that, although we endeavour to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches.
10.HOW TO CONTACT US
In processing your personal data, we act as a data controller. Our contact details are as follows: Resident Advisor, 26 Hertford Road, London, N1 5QT, [email protected].