1 Who are we and what do we do?
We are Twelve Ticketing B.V. (called, Twelve Ticketing, we and our). Twelve Ticketing offers a no-nonsense ticketing solution for every type of event you can think of. We support event organizations through delivering kick-ass software and off the hook service to start selling your tickets (our Services). Our website: www.twelveticketing.eu offers more information about us and our Services.
2 Twelve Ticketing and your Personal Data
Twelve Ticketing cares about your privacy and protecting your personal data. We process Personal Data – i.e. all information by which a person can be directly or indirectly identified – in line with the General Data Protection Regulation (GDPR) and other relevant legislation on the protection of Personal Data (collectively referred to as Relevant Legislation). This Privacy Policy explains what kind of Personal Data is collected via our Website and Services. It also explains the purposes for which Personal Data is used, how it is protected and the duration of its storage.
3 Twelve Ticketing acts as both Data Processor and Data Controller
Twelve Ticketing as Data Processor:
Most of the Personal Data we collect and process, are processed on behalf of the Clients who use our Services. Our Clients determine the means and purposes of this processing of Personal Data, which means they act as Data Controller within the meaning of the Relevant Legislation. We process these Personal Data strictly in accordance with the instructions of our Clients and we don’t process them for our own purposes. In this respect, we act as Data Processor within the meaning of the Relevant Legislation. Our obligations as Data Processor are laid down in the Data Processing Agreement we enter into with our Clients.
As Data Processor, we may collect and process for example the following (Personal) Data on behalf of our Clients:
• Contact information of ticket-holder: such as name, mail-address and phone number.
• Financial information of ticket-holder: such as IBAN-number and BIC-code.
For more information on the Personal Data we process as Data Processor and the relevant purposes, we refer to the privacy policies of our Clients. In case you contact us with a question regarding Personal Data we process as Data Processor, we will refer you to the relevant Client who acts as Data Controller in that respect.
Twelve Ticketing as Data Controller:
Apart from the processing of Personal Data on behalf of our Clients, we do collect and process some Personal Data for our own purposes. In this respect, we act as Controller ourselves within the meaning of the Relevant Legislation.
4 What Personal Data do we process as a Controller and for what purposes do we use them?
As Data Controller, we collect and process the following Personal Data:
Personal Data of (potential) Clients:
(Personal) data: Contact details
Your (company) name, e-mail address, Client number, telephone number, current ticketing information and any Personal Data included in your message.
We use these data to:
- Get in touch and to maintain contact with our (potential) Clients;
- Send newsletters. We may process these Personal Data in order to (possibly) enter into a contract or to execute an existing contact. For example, by a request to make ‘an offer you can’t refuse’ or to deliver our Services.
Legal basis:
We may send newsletters to existing Clients about similar products and services, because we have a legitimate interest to keep them updated about such products and services. We send newsletters to others than existing Clients only after we have obtained an explicit consent.
It is always possible to unsubscribe from our newsletter via the link at the bottom of each newsletter.
(Personal) data: Payment and taxing details
Client name and address, invoicing information (Services provided, prices, VAT rates), bank details (account number, IBAN and BIC-code) and an optional VAT identification number.
We use these data to:
- Send invoices to our Clients;
- Process and administer payments;
- Include in our (financial) administration to comply with the Tax and Customs Administration regulations.
Legal basis:
We may process these Personal Data, because we need these Personal Data to perform our contract with our Clients.
We are also legally obligated to process and/or share (some of) these data for/with the national tax authorities.
(Personal) data: Services history
Information on the history of Services already rendered to the Client. This includes among other things information about earlier correspondence, and (technical) reports on rendered Services.
We use these data to:
- Identify the Clients’ history of Services used.
Legal basis:
We may process these Personal Data because we have a legitimate interest to process these data in order to provide you good Services.
(Personal) data: Technical information
Information on the device used to access our Services, IP-address and information on the used browser.
We use these data to:
- Communicate in the language of the browser;
- Adapt our Website to the used device.
Legal basis:
We use these Personal Data because we have a legitimate interest to process these data in order to provide a good functioning Website.
Personal Data of our Employees:
(Personal) data: Employee file
Various Personal Data, among which information included in the employment agreement, payroll and financial information, tax details, identification, photo and notes on absence and performance.
We use these data to:
- Perform our employment agreement with our Employees.
- Provide/administer the necessary information to/for the Tax and Customs Administration;
- Keep track on vacation/leave days/sickness absence;
- Keep track on performance.
Legal basis:
We may process these Personal Data because we need these Personal Data to perform our contract with our employees.
We have a legitimate interest to track vacation/leave days/sickness absence in order to estimate the deployment of capacity and to distribute capacity where necessary.
We also have a legitimate interest to track performance, so we can monitor and where necessary support our employees
Apart from the above, we are legally obliged to process some of these Personal Data, for example based on tax regulations.
Personal Data of Job Applicants (Applicant):
(Personal) data: Contact details of Applicant
First name, surname, email address and telephone number.
We use these data to:
- Contact the Applicant about the application.
Legal basis:
We have a legitimate interest to process these Personal Data, because we need them to get in touch with the Applicant.
(Personal) data: Application information
Information provided by Applicant, for example: Personal Data included in the Curriculum Vitae and motivation letter, qualifications, working experience, photo, LinkedIn-profile, gender and day of birth.
We use these data to:
- Assess whether the Applicant suits the job and/or Twelve Ticketing and to determine which Applicant is the most suitable candidate.
Legal basis:
We have a legitimate interest to process these Personal Data as we need them to process and assess the applications.
(Personal) data: Information retained during application process
Notes from interviews, information received from referees and/or training institutions, and where applicable, results from assessments and/or psychological tests.
We use these data to:
- Assess whether the Applicant suits the job and/or Twelve Ticketing and to determine which Applicant is the most suitable candidate.
Legal basis:
We have a legitimate interest to process these Personal Data as we need them to process and assess the applications.
(Personal) data: Information from public sources
Information in public profiles, such as LinkedIn and other social networks (where applicable).
We use these data to:
- Assess whether the Applicant suits the job and/or Twelve Ticketing and to determine which Applicant is the most suitable candidate.
Legal basis:
We have a legitimate interest to process these Personal Data as we need them to process and assess your application. We only process information that is relevant for your application and you will get the opportunity to react to our findings.
Personal Data made public on our Social Network Pages:
(Personal) data: Information you make public, when you leave a comment or otherwise post something on our Social Media Pages.
We use these data to:
- Contact you via our Social Media Pages;
- Process your feedback left on our Social Media Pages.
Legal basis:
We may process these Personal Data, because we have a legitimate interest to process these data and you voluntarily made public such information.
Our Social Media Pages are also controlled by the social medium itself. Please check their own privacy policy’s, to see how each social medium handles your Personal Data:
Instagram: Privacy Settings & Information(opens in a new tab)
Facebook: Data Policy(opens in a new tab)
Twitter: Privacy Policy(opens in a new tab)
5 How long do we keep the Personal Data?
We store Personal Data for as long as we need it for the above purposes:
- Personal Data of potential Clients | This data is stored as long as necessary to determine whether we enter into an agreement and for a maximum period of 18 months after our last contact.
- Personal Data of existing Clients | This data is stored as long as we have a contract for our Services with the Client and for a maximum period of 18 months after, unless we are legally obliged to retain the data for a longer period.
- Personal Data of Employees | The Personal Data in the Employees file are stored as long as we have an employment agreement with the Employee and for a maximum period of 2 years after, unless we are legally obliged to retain the data for a longer period.
- Personal Data of Applicants | This data is stored for a maximum of 4 weeks after the application procedure is finished, unless we obtained your consent to restore your Personal Data for a maximum of 1 year after this moment.
- Personal Data in our records for the tax authorities | This data is stored for seven (7) years, unless we are legally obliged to retain the data for a longer period.
6 Do we share your Personal Data with others?
We use “Data Processors” to assist us in our Services. Within this context these Data Processors receive Personal Data from us which they process on our behalf. We use Data Processors, for instance, to host our e-mail and to store (Personal) Data. Our use of Data Processors is always in accordance with the Relevant Legislation.
Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.
7 Export of data outside the European Union
We may transmit Personal Data to parties outside the European Union, if one of our Data Processors is established outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the European standards.
The transmission of data outside the EU will always happen in conformity with the Relevant Legislation (chapter 5 of the GDPR).
8 How do we protect the Personal Data?
We protect all Personal Data we process from unauthorized and unlawful access, change, disclosure, use and destruction. For instance, we take the following technical and organizational measures to protect the Personal Data:
- Limited access to the (Personal) Data for authorized employees on a need-to-know basis.
- Encryption through passwords.
- Network connection with Secure Socket Layer (SSL) technology;
- Two factor authentication for accessing the (Personal) Data (optional);
- Password and data encryption;
- Split of application and database servers;
- Use of dedicated servers, not mixed with other potential harmful apps.
9 Amendments to this Privacy Policy
We aim to constantly improve our Website and Services. That is why from time to time we can update this Privacy Policy. If we change our Privacy Policy significantly, then we will state so on our Website together with the revised Privacy Policy.
10 Your rights and our contact data
As laid down in the Relevant Legislation, you have the right to:
- Ask us to rectify or update your Personal Data;
- Ask us to remove your Personal Data from our systems;
- Ask us for a copy of the Personal Data we process of you. We can also transmit such copy to another data controller at your request;
- Withdraw your consent to process your Personal Data. This only affects the processing activities that are based on your consent and does not affect the validity of such processing activities before you have withdrawn your consent;
- Object to the processing of your Personal Data;
- File a complaint with the Dutch Data Protection Authority, if you believe that we process your Personal Data unlawfully.
If you have any questions, comments or concerns regarding the manner in which we handle your Personal Data, please contact us through the contact data below.
11 Contact Data
Name: Twelve Ticketing B.V.
Address: De Holle Bilt 25
3732 HM De Bilt
The Netherlands
Mail: [email protected]
Ch. Of Comm: 69754020
VAT-number: NL857997865B01