1. INTRODUCTION
Your privacy is very important to us. We are committed to
ensuring that when you choose us to acquire your tickets, you know what
personal data we collect about you and how we use your personal data. We are
committed to protecting and respecting your privacy. This data privacy notice
(“Privacy Notice”) is a statement that describes how we will use your personal
data. Please take the time to read and understand our Privacy Notice.
2. WHO WE ARE?
MyTM Private Limited is an online
agent for the sale of tickets appointed and authorised by the event organisers.
Our ticketing platform operates through our website https://mypay.pk
3. SCOPE OF THIS NOTICE
This Privacy Notice (together with our End Users Terms of
Use and any other documents referred to on it) sets out the basis on which any
personal data we collect from you, or that you provide to us, will be processed
by us.
This Privacy Notice also sets out how you can instruct us
if you prefer to limit the use of that personal data and the procedures that we
have in place to safeguard your privacy.
Please read the following carefully to understand our
views and practices regarding your personal data and how we will treat it.
By using our websites or our Apps, registering with us or
submitting information to us you signify you have read and understood our
collection, use and disclosure of your personal information in accordance with
this Privacy Notice. If you do not agree with this Privacy Notice, you must not
use our Websites and our Apps, access our services or submit information to us.
4. INFORMATION WE MAY COLLECT (OR RECEIVE)
ABOUT YOU
4.1 We may collect (or receive) and process your personal
data when:
(a) you contact us, whether through our Websites, our Apps
or otherwise (for example, via our online form, by e-mail, post, fax or phone),
as we may keep a record of that correspondence. For example, if you submit a
complaint, report a problem with our service or our websites or our Apps or
otherwise liaise with our customer service, technical support or any other
department in our company;
(b) you update the information in your customer account or
you fill in and submit information on our websites or Apps via your PC, a
mobile device or otherwise such as your:
(i) name and address;
(ii) e-mail address;
(iii) username, password;
(iv) your IP address;
(v) your phone number;
(vi) Gender; and
(vii) Age.
(c) we ask you to complete surveys that we use for
research purposes, although, you do not have to respond to them;
(d) you use and interact with our websites or our Apps
including your device’s manufacturer and model, IP address, browser type and
version, time zone setting, browser plug-in types and versions, operating
system, web browser, platform, mobile carrier, and your ISP. We may collect
details of your visits to our websites or our Apps (including, but not limited
to, traffic data, location data, weblogs and other communication data). We do
this via email and website cookies, and similar tracking technology built into
our Websites and our Apps. We make cookie policies available on each of our
Websites and our Apps to give you more detailed information on how we use them;
(e) you use your customer account to log in or you use our
ticketing platform technology and other features, and functionality, including
our solutions and applications;
(f) we receive and then provide information about the
tickets you purchase and any relevant information about the events connected to
the ticket. Under no circumstances are these details disclosed to any third
parties other than those who need to know this information in the context of
the services we provide, such as the event organisers, venues and other
ticketing companies who might need it when they are running the box offices on
behalf of the event organiser;
4.2 We may have access to your financial information, such
as your billing address, bank account details and payment history in order to
allow us to take payments from you in connection with the tickets you purchase,
send you refunds or enable our customer service to deal with your enquiries.
4.3 We may have access to your social media content where
this is in the public domain, and any messages you send direct to us via social
media. This information can include posts and comments, pictures and video
footage on sites such as YouTube, Facebook and Twitter.
4.4 We may check some of the information that you provide
against third party databases to confirm that it is accurate.
5. HOW WE MAY USE THE INFORMATION
5.1 We may process your personal data for one or more lawful
bases of processing (“Lawful Basis”) depending on the specific purpose for
which we are using your data (see below).
5.2 We may process this information for the purpose of:
(a) dealing with your inquiries and requests, including
contacting you were necessary. Lawful Basis: your consent or performance of our
contract with you;
(b) notifying you about important changes or developments
to our Websites, our Apps or to our services (e.g., changes of features or
enhancements) Lawful Basis: performance of our contract with you or necessary
for our legitimate interests;
(c) carrying out our obligations arising from any
contracts connected to you, such as using the data you provide, or we collect
from you to make available to you the event tickets you purchase through us and
to send you information or updates about the events. Lawful Basis: performance
of our contract with you or necessary for our legitimate interests;
(d) providing and personalising our services. Lawful
Basis: performance of our contract with you or necessary for our legitimate
interests;
(e) providing you access to all parts or features of our
Websites, our Apps or our services. Lawful Basis: performance of our contract
with you or necessary for our legitimate interests;
(f) where applicable, processing your payments. Lawful
Basis: performance of our contract with you or necessary for our legitimate
interests;
(g) administering your registration and/or membership and
other customer accounts records. Lawful Basis: performance of our contract with
you or necessary for our legitimate interests;
(h) for market research, analysis and creating statistics.
Lawful Basis: your consent, performance of our contract with you or necessary
for our legitimate interests;
(i) to send you marketing communications, for instance, to
contact you from time to time regarding things you have told us you want to
hear about; new products, for example, or special offers, competitions and
sponsored events. If you use our Apps, we may use push notifications to
highlight when we have added new offers and promotions that may be of interest
to you. Lawful Basis: your consent or necessary for our legitimate interests;
(j) prevent, detect and investigate potentially prohibited
or illegal activities, and enforce our End Users Terms of Use. Lawful Basis: to
comply with our legal obligations or necessary for our legitimate interests;
(k) improving and developing our Websites, our Apps or our
services. Lawful Basis: performance of our contract with you or necessary for
our legitimate interests;
(l) ensuring that content from our websites is presented
in the most effective manner for you and for your computer or mobile device.
Lawful Basis: performance of our contract with you or necessary for our
legitimate interests;
(m) ensuring we have adequate security measures and
services so you can safely access our Websites and our Apps. Lawful Basis:
performance of our contract with you, to comply with our legal obligations or
necessary for our legitimate interests;
(n) comply with all the applicable laws and regulations.
Lawful Basis: to comply with our legal obligations;
(o) debt recovery or debt tracing, crime, fraud and money
laundering compliance. Lawful Basis: to comply with our legal obligations or
necessary for our legitimate interests;
(p) to run our customers areas including providing access
to customers and administering privileges, rewards and loyalty scheme points.
Lawful Basis: to comply with our legal obligations, performance of our contract
with you or necessary for our legitimate interests;
(q) to help us run competitions and special offers and
make sure you get all the benefits you are promised. Lawful Basis: your
consent, performance of our contract with you or necessary for our legitimate
interests;
(r) to collect feedback from you about our Websites, our
Apps, and other activities. For example, occasionally we may invite you to
review a mobile app you have bought or used from us. If we do, it is possible
that we will use independent research and feedback providers to act on our behalf.
Lawful Basis: your consent or necessary for our legitimate interests;
(s) for recruitment purposes if you have applied for a
position with us including to contact you to discuss a role with us and to
assess your suitability. Lawful Basis: your consent, performance of our
contract with you or necessary for our legitimate interests;
(t) to monitor how people use our Websites and our Apps to
see if they are being abused or threatened, for example, by internet trolls
posting inappropriate comments in review areas or by would-be hackers looking
to undermine our security. Lawful Basis: your consent, performance of our
contract with you or necessary for our legitimate interests;
(u) to allow us to understand our customer base across all
our businesses. We do this by merging your details with information from our
other customers of our Websites and our Apps. We can then spot trends and
common factors among customers, plus we can tailor our business approach, our
marketing communications, our digital and social media, our Websites and our
Apps to the things we believe you and other people like you would be most
interested in. This process involves the analysis of many human traits and is
sometimes called ‘market segmentation’ or ‘customer segmentation’. Among other
things, we look at common trends or ‘segments’ based on people’s geographic
location, online behaviours on our websites or our Apps. Lawful Basis:
processing is necessary for our legitimate interests;
(v) to test new systems and processes as we roll them out
to make sure they work correctly and meet the standards we set for ourselves.
Lawful Basis: processing is necessary for our legitimate interests; and
(w) to assist us in the development of new products and
our Apps over a period of time. For example, we may need to gauge whether a new
product or mobile app is likely to appeal to a large proportion of our customer
base. And if not, we will want to know why. Lawful Basis: processing is
necessary for our legitimate interests.
5.3 If you are an existing customer, we may contact you
with information, products or services that you request from us or ones which
are similar to the services we are providing to you (independently or jointly
with others), unless you opted out to be contacted for such purposes. We may
contact you for this purpose by post, telephone, fax, as well as by email. If
you change your mind about being contacted in the future, please let us know.
5.4 We do not sell, rent, or otherwise provide your
personal data to third parties unless you consent to this or it is necessary to
provide you with our services or as described in this Privacy Notice.
5.5 If you choose to post messages on any online forum or
other message platforms that we may make available for this purpose on our Apps
or our Websites, we may collect that information you provide to us. We may
process this information as necessary to respond to any social media posts or
other public comments you might make, whether they are directed to us or about
us, our Websites, our Apps or other activities, to resolve disputes, provide
customer support and troubleshoot problems, as permitted by law. Lawful Basis:
to comply with our legal obligations, performance of our contract with you and
necessary for our legitimate interests.
5.6 You may ask us to provide you with information about
our services or about services offered jointly with or on behalf of other
organisations by sending us an e-mail to [email protected]
5.7 If you stop using our Websites, our Apps or our
services or your permission to use our Websites, our Apps or our services is
terminated, we may continue to use and disclose your personal information in
accordance with this Privacy Notice (as amended from time to time) and as
permitted by law. However, if you wish us to stop e-mailing you with
information in connection with our Websites, our Apps or our services, please
unsubscribe or send your request to the contact details set out above.
6. CONTACTS INFORMATION
6.1 Where applicable, you can change your contact details
at any time by updating your profile in your customer account and update your
contact preferences by changing your settings related to your notification
choices.
6.2 We may use information you provide to us, or to third
parties offering combined services with us, to customize the services we
provide to you.
7. INFORMATION SECURITY
7.1 The Internet is not a secure medium. However, we have
put in place a range of security procedures, as set out in this Privacy Notice.
7.2 Where you have been allocated an account, this area is
protected by your user’s name and password, which you should never divulge to
anyone else.
7.3 Please be aware that communications over the Internet,
such as emails/webmail’s, are not secure unless they
have been encrypted. Your communications may route through a number of
countries before being delivered. This is the nature of the World Wide
Web/Internet.
7.4 We cannot accept responsibility for any unauthorised
access or loss of personal information that is beyond our control.
7.5 We will use reasonable endeavours to implement
appropriate policies, rules and technical measures to protect the personal data
that we have under our control (having regard to the type and amount of that
data) from unauthorised access, improper use or disclosure, unauthorised
modification, unlawful destruction or accidental loss.
7.6 We will ensure that your information will not be
disclosed to government institutions or authorities except if required by law (e.g.,
when requested by regulatory bodies or law enforcement organisations in
accordance with applicable legislation).
7.7 Certain services may include social networking, chat
room or forum features. When using these features please ensure that you do not
submit any personal data that you do not want to be seen, collected or used by
other users.
8. TO WHOM WILL YOUR INFORMATION BE
DISCLOSED?
8.1 Your information may, for the purposes set out in this
Privacy Notice, be disclosed for processing:
(a) to our employees, our Affiliates and their employees.
For instance, Ticket Arena and Event Genius are part of the Ticket Arena Group
and will share your information;
(b) if you purchase a ticket from us or any other services
connected to an event to the event organiser (e.g., we will share your data
with event organisers to enable them to allow entry to the events and to run
the events. They may send you marketing communications and other promotional
information by e-mail, SMS, post, phone, social media);
(c) to our third-party consultants, (sub-)contractors,
suppliers or other service providers who may access your personal information
when providing services (including but not limited to IT support services) to
us (e.g., for instance, we may share your data with email marketing companies
who help us to email or mail our newsletter to you and other people who help us
provide our Websites, our Apps, and related services to you. This includes
information technology experts who design and host our Websites and our Apps,
and general service companies).
(d) to auditors or contractors or other advisers auditing,
assisting with or advising on any of our business purposes;
(e) to analytics and search engine providers that assist
us in the improvement and optimisation of our websites or Apps;
(f) to our successors in title, our prospective sellers or
buyers of our business or to our Affiliates when we have a merger or
re-organisation;
(g) to government bodies and law enforcement agencies and
in response to other legal and regulatory requests;
(h) to any third-party where such disclosure is required
in order to enforce or apply our End User Terms of Use or other relevant
agreements;
(i) to protect the rights, property, integrity or security
of our company, our customers, or others (including, without limitation, you).
This includes exchanging information with other companies and organisations for
the purposes of fraud protection and credit risk reduction; and
(j) where you have consented to
this, to selected third parties that may contact you about products and
services which may be of interest to you in any jurisdiction where we operate.
8.2 Any social media posts or comments you send to us (on
our Facebook page, for instance) will be shared under the terms of the relevant
social media platform (e.g., Facebook or Twitter) on which they are written and
could be made public. Other people, not us, control these platforms. We are not
responsible for this kind of sharing. So before you make any such remarks or
observations, you should review the terms and conditions and privacy policies
of the social media platforms you use. That way, you will understand how they
will use your information, what information relating to you they will place in
the public domain, and how you can stop them from doing so if you are unhappy
about it.
8.3 Mobile app
platforms
(a) Our Apps run-on third-party software platforms, for
example, Apple’s iOS platform which powers Apple’s iPhone and Google’s Android
platform which powers Android-based smartphones.
(b) If you use any of our Apps, your usage of those Apps
is also subject to the relevant mobile app platform provider’s terms and
conditions and privacy policy. You should review their terms and conditions and
privacy policy to ensure you understand what information (if any) they will
gather about you, how they will use that information, and what you may be able
to do if you are unhappy about it.
9. YOUR RIGHTS IN RELATION TO YOUR
INFORMATION
9.1 You can write to us at any time to obtain a copy of
your information and to have any inaccuracies corrected.
9.2 You have the following rights, though, please note
that they do not apply in all circumstances:
(a) request access to your personal data (commonly known
as a "data subject access request");
(b) request correction of the personal data that we hold
about you;
(c) request erasure of your personal data. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the
time of your request;
(d) object to processing of your personal data where we
are relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which
override your rights and freedoms;
(e) request restriction of processing of your personal
data. This enables you to ask us to suspend the processing of your personal
data in the following scenarios: (a) if you want us to establish the data's
accuracy; (b) where our use of the data is unlawful but you do not want us to
erase it; (c) where you need us to hold the data even if we no longer require
it as you need it to establish, exercise or defend legal claims; or (d) you
have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it;
(f) request the transfer of your personal data to you or
to a third party. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information (i.e., not to hard
copies) which you initially provided consent for us to use or where we used the
information to perform a contract with you; and
(g) withdraw consent at any time where we are relying on
consent to process your personal data. If you withdraw your consent, we may not
be able to provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your consent.
9.3 Please write to: MyTM Building, 68 R1, phase two, Johar Town , Lahore, Pakistan.
9.4 Please quote your name and address. We should be
grateful if you would also provide brief details of the information of which
you would like a copy or which you would like to be corrected (this helps us to
more readily locate your data).
9.5 We will require proof of your identity before
providing you with details of any personal information we may hold about you.
9.6 We try to respond to all legitimate requests within 1
(one) month. Occasionally, it may take us longer than 1 (one) month if your
request is particularly complex or you have made a number of requests. In this
case, we will notify you within 1 (one) month of the receipt of your request and
keep you updated.
9.7 We may charge you a reasonable fee to you when a
request is manifestly unfounded, excessive or repetitive, or we receive a
request to provide further copies of the same information. Alternatively, we
may refuse to comply with your request in these circumstances.
10. COOKIES
10.1 We use cookies to store and collect information about
your use of our websites. Cookies are small text files stored by the browser on
your equipment's hard drive. They send information stored on them back to our
web server when you access our Websites. These cookies enable us to put in
place personal settings and load your personal preferences to improve your
experience. You can find out more about our cookies on our “cookies policy”
available on our website.
11. WHERE WE STORE AND PROCESS YOU
INFORMATION
11.1 The data that we collect from you may be transferred
to, and stored with one of our suppliers or Affiliate companies. Such staff may
be engaged in, among other things, the fulfilment of your request, the processing
of your payment details and the provision of support services. By submitting
your personal data, you agree to this transfer, storing or processing. We will
take all steps reasonably necessary to ensure that your data is treated
securely and in accordance with this Privacy Notice.
12. YOUR CONSENT AND CHANGES TO THIS PRIVACY
NOTICE
12.1 We reserve the right to amend or modify this Privacy
Notice and if we do so we will post the changes on our Websites and on our
Apps. It is your responsibility to check the Privacy Notice every time you
submit information to us.
12.2 In the event that the purposes for processing
personal information change, we will contact you as soon as practicable and
seek your consent where such notification relates to a new additional purpose
for processing.
13. USE OF YOUR PERSONAL INFORMATION
SUBMITTED TO OTHER WEBSITE
13.1 Except as otherwise expressly included in this
Privacy Notice, this document addresses only the use and disclosure of
information we receive about you or collect from you.
13.2 If you disclose your information to others (e.g.,
websites we link to), different rules may apply to their use or disclosure of
the information you disclose to them. We are not responsible for the privacy
policies and practices of other websites even if you accessed the third-party
website using links from our websites.
13.3 We recommend that you check the policy of each
website you visit and contact the owner or operator of such website if you have
concerns or questions.
14. DATA RETENTION
14.1 We will only retain your personal data for as long as
you have consented to it or when is necessary to us to provide you with our
services or fulfil the purposes, we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements or any
legal or regulatory requirements.
14.2 To determine the appropriate retention period for
personal data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether
we can achieve those purposes through other means, and the applicable legal
requirements.
14.3 In some circumstances you can ask us to delete your
data.
14.4 In some circumstances we may anonymise your personal
data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.
15. FURTHER INFORMATION
15.1 If you would like to let us know about something we
have done, or failed to do, whether positive or negative, please let us know.
Your comments enable us as an organisation to learn and continuously improve
our services.
15.3 Questions, comments and requests regarding this
Privacy Notice should be addressed to FAQ Client Services Director, [email protected]
16. YOUR DUTY TO INFORM US OF CHANGES
16.1 It is important that the personal data we hold about
you is accurate and current. Please keep us informed if your personal data
changes during your relationship with us.
16.2 If your personal details change, please help us to
keep your information up to date by notifying us at [email protected]