Privacy policy

Privacy Policy

Last Updated:  10/27/2020

23/7 Global Inc. (“Company,” “we,” or “us”), is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we or our third-party service providers collect through our owned or controlled websites and web properties (e.g., widgets and applications) and mobile applications (“Mobile Apps”) through which you are accessing this Privacy Policy (collectively the “Properties”).

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including Facebook, Inc., Apple Inc., Google Inc., Microsoft Corp., Blackberry, any wireless carriers, our artists, our affiliates and any third party operating any site or property to which any Property contains a link. In addition, the inclusion of a link on any Property does not imply endorsement of, or affiliation with, the linked site or Property by us or by our artists or affiliates. Please note that the Properties may include the ability to access and submit (including, for example, via a third-party software application or service that is available through or in connection with a Property) certain information directly to third parties such as Facebook or to any application platform such as Apple’s App Store or Google Play. Such information is submitted by you directly to such third parties, and this Privacy Policy does not apply to any such information.

If you are a California resident, please see the “Additional Information Regarding California” section at the end of this Privacy Policy for further information on our collection and use of your personal information.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we make the revised Privacy Policy available on or through a Property. Your use of such Property following such changes means that you accept the revised Privacy Policy.

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including, for example:

• Name
• Postal address
• Telephone number
• Email address
• Credit and debit card number

We may use a third-party payment service to process payments made through the Properties. If you wish to make a payment through the Properties, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

How We May Collect Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Properties: We collect Personal Information through the Properties, such as when you register or make a purchase.
• Offline: We collect Personal Information from you offline, such as when you place an order over the phone or contact customer service.
• From Other Sources: We receive your Personal Information from other sources, such as companies from which you have purchased tickets, products or services that we fulfill; public databases; joint marketing partners; social media platforms; and other third parties.

We need to collect Personal Information in order to provide the requested products and services to you. If you do not provide the information requested, we may not be able to provide the Properties or our products or services. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Properties, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for our legitimate business purposes, including:

• Providing the functionality of the Properties and fulfilling your requests.

• To respond to your inquiries and fulfill your requests, when you contact us via one of our online forms or otherwise, for example, when you send us questions, or when you request information about our products and services.
• To send you administrative information, including information regarding the Properties and changes to our terms, conditions and policies.
• To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
• To allow you to send messages (for example, music clips or artist information) to a friend through the Properties, if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials.

• To send you marketing related push notifications, emails, and text messages, with information about our services, products and other news about our company.

We will engage in this activity with your consent (if required by applicable law) or where we have a legitimate interest.

• Analysis of Personal Information for business reporting and providing personalized services.

• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve the Properties.
• To better understand you, so that we can personalize our interactions with you and your experience on the Properties, including by presenting information, content, products and offers tailored to your interests.

We will provide personalized services either with your consent or because we have a legitimate interest.

• Allowing you to participate in sweepstakes, contests or other promotions.

• We may offer you the opportunity to participate in sweepstakes, contests and other promotions. Some of these activities have additional rules with information about how we use and disclose your Personal Information.

We use this information to manage our contractual relationship with you.

• Aggregating and/or anonymizing Personal Information.

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

• Accomplishing our business purposes.

• For data analysis, for example, to improve the efficiency of our Properties.
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• For developing new products and services.
• For enhancing, improving or modifying our current products and services.
• For identifying usage trends, for example, understanding which parts of our Properties are of most interest to users.
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
• For operating and expanding our business activities, for example, understanding which parts of our Properties are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or because we have a legitimate interest.

Disclosure of Personal Information

We disclose Personal Information:

• To our third-party service providers, to facilitate services they provide to us.

• These can include providers of services such as hosting, data analysis, payment processing, order fulfillment, information technology and infrastructure provision, customer service, email delivery, auditing and other services.
• To third parties, to permit them to send marketing communications to you, consistent with your choices.

• Such third parties include our artists (including any of the artists’ band members, if applicable) and their representatives, including, for example, if you (a) sign up to join the applicable artist’s mailing list and/or to receive such artist’s newsletters, (b) register with the applicable artist’s website, or (c) have otherwise indicated that you would like to receive information and/or marketing communications from the applicable artist. We do not control, and are not responsible for, artists’ and their representatives’ use of Personal Information.
• To third parties that sponsor contests, sweepstakes and similar promotions.
• By using the Properties, you may elect to disclose Personal Information.

• To anyone to whom you send messages on or through the Properties.
• On message boards, chat, profile pages, blogs and other services to which you are able to post information and materials. Please note that any information and materials that you post or disclose on or through a Property may be available to visitors to such Property and to the general public and may be redistributed through the Internet and other media channels where they will reach an even broader audience. Additionally, please note that, per our Terms of Use located at https://237global.com/legal/#termsofuse, we retain certain rights in the information and materials that you post on or through the Property, and we may use and disclose such information and materials (including any Personal Information included therein) in accordance with our Terms of Use. We urge you to be very careful when deciding to disclose information on or through the Properties. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF ANY INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY PROPERTY.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

• This can include laws outside your country of residence.
• To cooperate with public and government authorities.

• To respond to a request or to provide information we believe is important.
• These can include authorities outside your country of residence.
• To cooperate with law enforcement.

• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.

• To enforce our terms conditions.
• To protect our rights, privacy, safety or property and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.

• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding). Such third parties may include, for example, an acquiring entity and its advisors.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Properties or otherwise to us.

OTHER INFORMATION

“Other Information” is information that does not reveal your specific identity or does not directly relate to an identifiable individual. We and our third-party service providers may collect Other Information, such as:

• Browser and device information
• Mobile App usage data
• Server log files
• Information collected through cookies, pixel tags and other technologies
• Geographic location information
• Demographic and other information provided by you
• Information about how you use the Properties

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

How We Collect Other Information

We and our service providers collect Other Information in a variety of ways, including:

• Through your browser or your device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Mac), screen resolution, operating system version, Internet browser type and version and the type and version of a Property that you are using. We use this information to ensure that the Properties function properly.
• Through your use of Mobile Apps: When you download and use a Mobile App, we and our service providers may track and collect Mobile App usage data, such as the date and time the Mobile App on your device accesses our servers and what information and files have been downloaded to the Mobile App based on your device number.
• Through server log files: An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing a Property by your Internet Service Provider and is identified and logged automatically in our server log files whenever you visit the Property, along with the time of the visit and the activity on the Property. We and our service providers use IP addresses for purposes such as calculating Property usage levels, helping diagnose server problems, administering the Properties and determining your approximate geographic location.
• Using cookies: We and our service providers may use cookies, pixel tags, web beacons, and other similar technologies to, among other things, better serve you with more tailored information, facilitate your ongoing access to and use of the Properties, and collect and store information about your use of the Properties. For example, pixel tags and web beacons may be used to, among other things, track the actions of a Property’s users, measure the success of marketing campaigns and compile statistics about a Property’s usage and response rates.

• If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. If you choose to decline cookies, then some or all of the features, functionality and promotions available through the Properties may not be available to you.
• We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Properties and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Our Properties do not currently respond to browser-based do-not-track signals.
• Geographic location information: If you use any location-enabled products or services, you may be sending us location information. When you use a location-enabled service, we may collect and process information about your precise geographical location, such as GPS signals sent by a mobile device. We and our service providers and partners may use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
• From you: We may collect demographic and other information, such as your age or gender, when you voluntarily provide it to us. Unless combined with Personal Information, this information does not personally identify you.
• Information about how you interact on the Properties: We may collect information about how you interact on the Properties. For example, some Properties may utilize analytic tools to help us better serve you through improved products, services, and revisions to the Properties. This information may let us know which services and features you are using the most within a Property, as well as device type and hardware features, country and language of download, etc.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. We may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data security system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHILDREN

The Properties are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16) through the Properties.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Properties, you understand that you are transferring your information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your Personal Information.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

• Receiving marketing-related emails from us: If you do not want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the unsubscribe mechanism provided in the email.
• Receiving text messages from us: If you do not want to receive text messages from us on a going-forward basis, you may reply “STOP” to any such message in order to opt-out of receiving similar such messages.
• Receiving push notifications from us: If you do not want to receive push notifications from us, you may opt out using your device settings.
• Our sharing of your Personal Information with third parties for their marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with third parties for their marketing purposes, you may opt-out from such sharing by emailing us at info@237global.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that, if you opt-out from receiving marketing-related messages from us, we may still send administrative messages to you, from which you cannot opt-out.

How you can access, change or delete your Personal Information and Posted Content

If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us or content you have previously posted on a Property, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at info@237global.com. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Privacy Policy for more information about the requests you may make under California law.

In your request, please make clear what Personal Information or posted content you would like to have changed or removed, or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. We may need to retain certain information or content for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (1) the length of time we have an ongoing relationship with you and provide the Properties to you (for example, for as long as you have an account with us or keep using the Properties); (2) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and (3) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

CONTACTING US

23/7 Global Inc., located at 32 West 22nd Street, New York, NY 10010, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at info@237global.com or:

23/7 Global Inc.

32 West 22nd Street

New York, NY 10010

Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.

FOR NEVADA RESIDENTS

We do not sell Covered Information as defined under Nevada law. If you would like to make any inquiry regarding the sale of your Covered Information, please contact info@237global.com.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed for a business purpose within the preceding 12 months:

• We collected the following categories of Personal Information:

• Identifiers, such as name, address, account name and IP address;
• Personal information, as defined in the California safeguards law, such as contact information and financial information;
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as device location;
• Audio, electronic, visual and similar information, such as call and video recordings; and
• Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

As described above, we collect this Personal Information from you as well as from other categories of sources, such as companies from which you have purchased tickets, products, or services that we fulfill, public databases, joint marketing partners, and social media platforms. As also described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.

• We disclosed the following Personal Information to third parties, such as our service providers and business partners, for our operational business purposes:

• Identifiers, such as name, address, account name and IP address;
• Personal information, as defined in the California safeguards law, such as contact information and financial information;
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as device location;
• Audio, electronic, visual and similar information, such as call and video recordings; and
• Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

(4)  If you are a California resident, you may request that we:

(A) Disclose to you the following information covering the 12 months preceding your request, pursuant to our obligations under the CCPA:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting [or selling] Personal Information about you and;
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(B)  Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at https://237global.com/fan-support/ or info@237global.com. We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

ADDITIONAL INFORMATION REGARDING THE EEA

You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

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